How are banks handling a cross-sell or firm offer of a credit product at DDA account opening that is not consumer initiated? Obvioulsly, if using a credit score at DDA open, the Bank is prohibited from using that same score to offer a credit product without being in violation of FCRA permissable purpose requirements.
So, my thinking is that a Pre-screening process is the only answer to the delima. I am just getting hung up on how other institutions are doing a proper pre-screening process at DDA account opening to offer a credit product that also complies with the FFIEC policy statement for prescreening.
Any ideas, vendors, or solutions?
Any input is appreciated.
Opinions expressed are my own and do not necessarily reflect those of my employer.