Ask the FDIC that while giving serious consideration to their suggestion, you were wondering about the implications under the FCRA for pulling a credit report for review purposes based on the FTC staff opinion:
" Staff believes that the “review†permissible purpose applies only where the creditor has an existing account relationship with the consumer and uses the report solely to decide whether to modify the terms of the account."
Remember, the examiner making this recommendation was most likely a safety and soundness examiner and not a compliance examiner. I would get clarification from the FDIC regional office before jumping headlong into such a process.
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