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#652962 - 12/15/06 07:34 PM Debit card & adverse action
Rooster Offline
Member
Joined: May 2006
Posts: 50
Scenario:
Customer applies for a visa/debit card and has a couple of charged off credit cards long ago. We don't want to give them a visa/debit card, but will give them an ATM card. Do we need to send out an adverse action b/c we denied them a certain type of card--is this considered "credit" per Reg B?

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#654065 - 12/19/06 03:37 PM Re: Debit card & adverse action Rooster
Bear Collector, CRCM Offline
Diamond Poster
Bear Collector, CRCM
Joined: Nov 2000
Posts: 1,830
District of Columbia
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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