I just have a couple comments, neither of which are based on legal fact or (of course) opinions of my employer. As a bank, you can kind of run credit on an accountholder any time you have a LEGITIMATE concern abount possible fraudulent or illegal activity. I would caution against an added disclosure about annual reports- I would actually lean more towards random reports. If an employee is doing something bad, knowing that a report will be annual is too easy. Also, at least in Illinois, make sure when you run a credit check at time of hiring, that you are pulling that report in the subscribed method that will not display an inquiry on their credit history. Again, all of this is my opinion as I head out the door for the day. My employer thinks I have left already anyway, so this can't be a reflection of them.