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#2087835 - 07/13/16 08:35 PM credit cards - pre-approved, pre-selected???
needHELP! Offline
Junior Member
Joined: Jan 2013
Posts: 47
We're in the "let's check and see what we can do stage".
We want to promote/advertise credit cards. Can someone point me in the right direction or help me with if we can or shouldn't do this.
Management wants to pre-approve some of our existing customers based on criteria such as average deposit balance, no insufficients, etc. We will not be obtaining prescreening information from a credit bureau, nor will we be taking into consideration if the customer has a loan with us, and if they do, we will not be reviewing the credit report or credit score on file. We want to offer a preapproved small dollar amount credit card to "good" deposit account holder customers.

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#2087884 - 07/14/16 01:40 AM Re: credit cards - pre-approved, pre-selected??? needHELP!
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,422
Galveston, TX
If you are using criteria only based on your own account experiences, then all you have to worry about is fair lending.
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#2087924 - 07/14/16 01:17 PM Re: credit cards - pre-approved, pre-selected??? needHELP!
Rocky P Offline
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Joined: Jun 2003
Posts: 7,659
Florida
Besides Randy's answer consider that having cash and having credit are two separate things, that may or may not relate to each other.

So you have a bankrupt person that got a subsequent large settlement that is sitting in your bank. Give them a card? They meet all the criteria. I do not believe that settoff is allowed if the credit card heads south.
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#2088051 - 07/14/16 05:27 PM Re: credit cards - pre-approved, pre-selected??? needHELP!
needHELP! Offline
Junior Member
Joined: Jan 2013
Posts: 47
Thank you both for your responses!!
If I'm understanding what I'm reading in Reg Z, we are also permitted to mail consumers a credit card application as a marketing tactic as long as we provide the Reg Z tabular format disclosure found in appendix G in the direct mailing. Is that your understanding as well?

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