I have a question concerning the FCRA & AANs.
Our bank used Chex Systems when denying a consumer a checking account. It was always my understanding that Chex Systems is a CRA but not a national CRA.
From what I have read, Section 615 of the FCRA does not specifically require that it be a national CRA.
However, we do not check the box, “our decision was based, at least in part, on information in a consumer report obtained from the CRA agency listed below." We do not provide any of the required FCRA disclosures. At the bottom of the AAN we check the box, “our decision was based in whole or in part on information obtained from an affiliate or from an outside source other than a CRA….”
I am thinking that this is incorrect and that we should be disclosing that Chex Systems is a CRA…. Am I correct?
Thank you!