Skip to content
BOL Conferences
Thread Options
#808306 - 09/04/07 03:56 PM "Notice of Negative Information" on disclosures??
HubbaBubba Offline
Gold Star
Joined: Sep 2002
Posts: 311
If we periodically pull credit reports or a Chex Systems report on new accounts, so we could potentially deny opening an account due to what is in these reports, do we need to have the Reg V "Notice of Negative Information" verbiage in our new deposit account disclosures?

Return to Top
Deposits and Payments
#808839 - 09/04/07 09:53 PM Re: "Notice of Negative Information" on disclosures?? HubbaBubba
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
This notice is only necessary if your institution FURNISHES info to a consumer reporting agency.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#810010 - 09/06/07 01:40 PM Re: "Notice of Negative Information" on disclosures?? David Dickinson
HubbaBubba Offline
Gold Star
Joined: Sep 2002
Posts: 311
Thanks avid - Yes, we DO report info to Chex Systems - so I do need some type of verbiage on our new account disclosures, correct?

Return to Top
#810290 - 09/06/07 04:46 PM Re: "Notice of Negative Information" on disclosures?? HubbaBubba
trail hiker Offline
Gold Star
Joined: Jul 2007
Posts: 436
David, am I correct in my belief that the notice of negative information can be on the past due notices that go out to the loan customers and that this past due notice can be the first time the loan customer receives the notice of negative information disclosure? Our first past due notice goes out to the customer about 15 days prior to the negative report to the credit bureau.

Return to Top
#810308 - 09/06/07 04:55 PM Re: "Notice of Negative Information" on disclosures?? HubbaBubba
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Originally Posted By: HubbaBubba
Thanks avid - Yes, we DO report info to Chex Systems - so I do need some type of verbiage on our new account disclosures, correct?


Chex Systems for the purposes of the Notice of Negative Information is not a consumer reporting agency. It only applies to the "big 3".

Quote:
David, am I correct in my belief that the notice of negative information can be on the past due notices that go out to the loan customers and that this past due notice can be the first time the loan customer receives the notice of negative information disclosure? Our first past due notice goes out to the customer about 15 days prior to the negative report to the credit bureau.


I'm not answering for David but yes your assumption is correct.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#810318 - 09/06/07 05:00 PM Re: "Notice of Negative Information" on disclosures?? Dan Persfull
trail hiker Offline
Gold Star
Joined: Jul 2007
Posts: 436
Thank you, Dan. Operations wants to eliminate the negative information notice that is part of our loan closing packets.

Return to Top
#810356 - 09/06/07 05:24 PM Re: "Notice of Negative Information" on disclosures?? trail hiker
waldensouth Offline
Power Poster
waldensouth
Joined: Nov 2001
Posts: 7,984
FINALLY ABOVE the gnat line
We put it on our 1st past due notice - "we may report you" and on the 30 day past due notice we put "we have reported you" language. We also include the "we may report you" statement in our privacy disclosure each year so all new customers receive it and all existing customers receive it as part of the annual mailing. I no longer have to think about it.
_________________________
"Once you learn to read, you will be forever free."

- Frederick Douglass




My Opinion Only.

Return to Top
#810452 - 09/06/07 06:13 PM Re: "Notice of Negative Information" on disclosures?? waldensouth
trail hiker Offline
Gold Star
Joined: Jul 2007
Posts: 436
I will pass this onto operations. Thanks.

Return to Top
#810676 - 09/06/07 08:20 PM Re: "Notice of Negative Information" on disclosures?? trail hiker
TexasBankerGirl Offline
Member
TexasBankerGirl
Joined: Oct 2006
Posts: 85
Texas

Return to Top

Moderator:  John Burnett