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#2096661 - 09/01/16 06:48 PM Bill Pay and Adverse Action
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
If an existing customer requests online banking with bill pay, and we deny them access to bill pay due to negative history (too many overdrafts), do we need to provide them with an adverse action notice if a credit report was not used?
Thank you!!

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eBanking / Technology
#2096665 - 09/01/16 06:55 PM Re: Bill Pay and Adverse Action ComplianceGurl, CRCM
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,651
Galveston, TX
No. As long as the negative history was with you.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2096680 - 09/01/16 07:36 PM Re: Bill Pay and Adverse Action rlcarey
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
Exactly what I was hoping to hear!! Thank you Randy!

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