If a bank refuses to open a checking account,(no credit bureau report pulled) does an adverse action notice need to be sent to the applicant?

If a bank freezes an ODP, because of history of payment, or lack thereof, does an adverse action notice need to be sent to the customer.

No adverse action notice is needed if you deny a checking account because of a reason other than credit bureau report.

An adverse action might be required if you freeze an ODP. Look in Reg. Z under notices 202.9 I think. There was an exclusion but I don't remember whether that was for a delinquency.

We've sent the adverse action on checking accounts because of the TelCheck report.......and to ensure that we were in compliance.....we could never decide whether TelCheck was considered a credit report or not.....................I suppose that we are taking a step that may not be necessary......

Thanks for the info on Reg B

Actually that would be Reg. B 202.9. But you want to look to Reg. B 202.2 for the definition of adverse action. If action is taken on an account due to delinquency that is not adverse action.


TelCheck would be considered a consumer reporting agency.