Reg B may not apply, but FCRA would. It really doesn't matter whether you consider this "credit" or not. Bottom line, if you deny a bank service based on 3rd party credit information, you need to send the customer a FCRA Notice explaining the reason for the denial and their rights under FCRA. (FCRA applies to jobs or insurance, neither of which is "credit.") FCRA defines adverse action as "an action taken or determination that is made in connection with an application that was made by, or a transaction that was initiated by, any consumer ...and...
adverse to the interests of the consumer."
BC
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Being kind is more important than being important.