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#821462 - 09/24/07 02:43 PM Adverse action for denial of debit card
Deanna Offline
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Joined: May 2004
Posts: 20
When a debit card is denied to customer due to credit report, which model of adverse of action is required? Bankers on line guru Jim Bedsole stated that is not the same notice of action taken form required for credit denials under Reg B. Could someone supply me with a model form? Thanks!
Last edited by Deanna; 09/24/07 02:45 PM.
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#821494 - 09/24/07 03:26 PM Re: Adverse action for denial of debit card Deanna
ToTo Offline
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Joined: Apr 2004
Posts: 595
OZ
There is no "model form". You need to look at section 615 of FCRA (15 USC 1681m) for the requirements of the notice.

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#821683 - 09/24/07 05:52 PM Re: Adverse action for denial of debit card ToTo
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
ToTo is right. You can send them a "standard" credit denial although, the Reg B portion (reasons, regulator's name and ECOA statement) are not necessary, or you can just give them the FCRA info.

The bank must provide the consumer with:
1. The name, address and telephone number of the credit bureau (including a toll-free telephone number established by the agency if the agency compiles and maintains files on consumers on a nationwide basis) that furnished the report to the bank;
2. A statement that the credit bureau did not make the decision to take the adverse action and is unable to provide the consumer the specific reasons why the adverse action was taken; and
3. A notice of the consumer’s right:
a) to obtain a free credit report within 60 days of the adverse action; and
b) to dispute the accuracy or completeness of any information in the consumer report with the credit bureau.
_________________________
David Dickinson
http://www.bankerscompliance.com

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