Does anyone pull a Chex Systems soft credit report when opening deposit, savings and time accounts, and if so do you keep the report in the customer's account file. It is my understanding that we should not pull a report for time deposit accounts unless we have the customer sign authorization because this account could not typically be overdrawn. It was also recommended to us, not to maintain copies of the reports once pulled. I have not found anything that says the reports cannot be maintained, we just have to ensure that the customer's privacy is maintained. Any advise?

You are entering into a business transaction with the customer and therefor have a "permissible purpose" to pull a report. There is no differentiation regarding what that business transaction may be.

"It was also recommended to us, not to maintain copies of the reports once pulled. " Recommended by who and why? There should be no reason not to keep a copy if you so choose. You just have to make sure that your eventual disposal processes are sound.

If an individual is opening a joint deposit account, is it permissible to pull credit on both account holders? Do you need any type of permission from the applicant whom is not present? Is there any different requirements if the credit will be pulled for cross selling loan products as well? TY!

If it is joint account and both people apply you have a permissible purpose. How do you let a present person nominate a non-present person on a joint deposit account. You need a signature and to do CIP. It would be a matter of documentation of intent to enter a business transaction with the bank.

You cannot use credit reports for marketing purposes. See the Gowan letter:

http://www.ftc.gov/os/statutes/fcra/gowen.shtm

Are credit reports permitted to be used for marketing purposes as long as a firm offer is made? Is that correct? FCRA[604(c)(1)(B). Thanks!

You are referring to prescreened lists. If you pull a prescreened list then you have to make a firm offer of credit to everyone that appears on the list that you get back from the credit bureau. You can't use a credit report that you pulled for another purpose for marketing under any conditions.

What compliance training requirements are needed for the deposit function of the bank on FACT act. We use Chex Systems for opening new checking accounts. I am also working on the policy and procedures and trying to find out the latest provisions that are effective.