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#2236694 - 05/14/20 05:34 PM Decline Message for Online Account Opening
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
We are in the process of rolling out online account opening. An applicant can pass ChexSystems/OFAC, but "fail" the account opening process for answering questions derived from public sources incorrectly. I'm looking for sample language for the "denial" email for this circumstance.
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eBanking / Technology
#2236695 - 05/14/20 05:38 PM Re: Decline Message for Online Account Opening TryingtoComply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
Why would you have to say anymore than "Your attempt to open an online account has been denied. Please visit our nearest branch location for assistance"?
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#2236698 - 05/14/20 05:53 PM Re: Decline Message for Online Account Opening TryingtoComply
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,716
Illinois
Right. FCRA doesn't apply to identification questions and we're not denying an extension of credit when denying a deposit account so there's no Reg B adverse action, either.

We could also say, "Thank you for playing our game. We have some lovely parting gifts for you!" Ok, Randy's option is more professional.
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#2236699 - 05/14/20 05:58 PM Re: Decline Message for Online Account Opening TryingtoComply
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
...so the declined applicant parks in front of the locked front door of the nearest branch and reads your COVID-19 notice...still no closer to opening the account.
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#2236706 - 05/14/20 06:34 PM Re: Decline Message for Online Account Opening TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
Randy/Brian - I agree that there is no need to go into any detail and that the response should be general with a number to call or invitation to visit a branch. I offered to explore this as part of my role on the committee working on this project.

Richard - Too funny - totally agree. Our modified lobby hours are only four hours per day right now. Good luck! LOL!
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