We pull credit reports from a credit reporting agency for deposit account qualification. I have always understood that since we are not offering a credit product, then Reg B isn't triggered. Which would mean that I don't have to provide a reason for not opening the account (as you would typically find on a loan adverse action).

However, we have a minimum credit score that must be met. Does that change anything about what information must be included in the denial form?

Should deposit adverse action notices/denials be retained for 25 months, also?

Thank You!

You do not have to give reasons but you have to include the score range, the score and the score reasons along with the CRB info. There are no specific retention periods in the FCRA, but a consumer can take action within two years of discovery or five years from the date of action. See Section 618.

Thank you so much for this information. I really appreciate the reference on the section.

Tagging on to this post...In looking at the disclosure requirements for FCRA adverse action notices, subparagraph D of section 609(f)(1) says we must provide notice that includes the date on which the credit score was created. In an online deposit account opening environment, must the score date be listed out separately, or does the date of the electronic notification (email) suffice since we deliver the notice at the time the negative report is generated?