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#2256591 - 07/12/21 09:52 PM FCRA Permissible Purpose
corporate audit Offline
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Joined: May 2008
Posts: 31
If a customer requests to open a small business banking deposit account, does the Bank have to get the customer's consent to pull a Qualifile? Or does the request fall under a reason in Section 604 (a) (3)( F) otherwise has a legitimate business need for the information ?

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Deposits and Payments
#2256596 - 07/12/21 11:04 PM Re: FCRA Permissible Purpose corporate audit
Inspector Offline
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Joined: Apr 2016
Posts: 250
What is the pull being used for?
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#2256598 - 07/13/21 01:07 PM Re: FCRA Permissible Purpose corporate audit
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 76,933
Galveston, TX
Also - define a small business - you mean an actual business entity?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2256623 - 07/13/21 05:29 PM Re: FCRA Permissible Purpose corporate audit
corporate audit Offline
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Joined: May 2008
Posts: 31
A Qualifile is pulled for the business entity, as well as individuals acting on behalf of the business entity, such as the custodian, guardian, rep payee, trustee, and executor/administrator.

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#2256624 - 07/13/21 05:38 PM Re: FCRA Permissible Purpose corporate audit
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 76,933
Galveston, TX
I was not aware that Qualifile handled business entity files - but regardless, unless the individuals you are running are going to be directly liable on the deposit account, you do not have a permissible purpose and I am not aware that CheckSystems allows you to run a report based on written permission.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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