We pull combination ChexSystems/Equifax consumer reports when new customers open deposit accounts with us. However, we have been asked about waiving the requirement to obtain the consumer reports for a request to open a large number of Christmas Club savings accounts from a local utility department which they will be regularly depositing on behalf of their employees. From a risk standpoint, these are savings-only accounts, it's not like a transaction account with ODP where a review of the consumer report could be beneficial before-hand. However, should we have any concern from a fair lending standpoint? I'm pretty sure there are no fair deposit laws, but would there be any reason we should not waive obtaining the consumer reports? Could it possibly be claimed some have inquiries on their consumer reports while others do not, resulting in disparate treatment? I feel as if I'm grasping at straws but want to ensure I am conservative in considering any effects the practice could have on our Bank.

Yes - grasping at straws. No reason to pull credit when opening a savings account. What risk is there to mitigate? .There is no "fair" considerations present.