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#1798383 - 03/26/13 05:16 PM Trust Department & Red Flag Assessment
Anonymous
Unregistered

I received a question from my bank's risk management department who is not familiar with trust departments. The question deals with whether or not the trust department utilizes consumer reporting agency(ies) for fraud alerts.

We don't utilize consumer reporting agencies to assist in monitoring our clients. Does anyone else?


QUESTIONS - WHETHER OR NOT....:
1. A fraud or active duty alert is included with a consumer report.
2. A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report.
3. A consumer reporting agency provides a notice of address discrepancy, as defined in the regulation.
4. A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer (such as a recent and significant increase in the volume of inquiries, an unusual number of recently established credit relationships, a material change in the use of credit, especially with respect to recently established credit relationships, or an account that was closed for cause or identified for abuse of account privileges by the organization or a creditor).

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#1798465 - 03/26/13 07:43 PM Re: Trust Department & Red Flag Assessment Anonymous
Anonymous
Unregistered

We looked into obtaining credit reports for our trust department on our trust clients and were advised that unless that trust client had a loan request we did not have a permissible reason to acquire a credit report.

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#1798503 - 03/26/13 08:42 PM Re: Trust Department & Red Flag Assessment Anonymous
Compli(cated) Offline
100 Club
Joined: Mar 2011
Posts: 185
Wisconsin
This might just be a side-note, but chexsystems is also considered to be a consumer reporting agency. If you run your clients through chexsystems as part of account opening, that would count.
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#1798505 - 03/26/13 08:43 PM Re: Trust Department & Red Flag Assessment Anonymous
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,474
Midwest
We do have a Trust Dept and we do not obtain consumer reports for those accounts.

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