Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Banker Forums General Discussion Debit Card Denials
Thread Options Tools
#194803 - 05/27/04 05:46 PM Debit Card Denials
ldsnanny3 Offline
100 Club
ldsnanny3
Joined: Nov 2003
Posts: 205
Georgia
When we deny a Debit Card based on the history we have with the customer, do we have to send any kind of Adverse Action Notice or FCRA notice. (Our history only, we did not pull a credit report)

Thanks


Return to Top
General Discussion
#194804 - 05/27/04 06:00 PM Re: Debit Card Denials
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,749
On the Net
No. If a loan isn't involved, the AAN is moot. If you are not using a credit report, the FCRA is out.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top
#194805 - 05/27/04 06:15 PM Re: Debit Card Denials
ldsnanny3 Offline
100 Club
ldsnanny3
Joined: Nov 2003
Posts: 205
Georgia
Andy,

If we do pull a credit report and deny a customer a debit card, how long do we have to send the FCRA notice?

thanks

Return to Top
#194806 - 05/27/04 06:21 PM Re: Debit Card Denials
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,749
On the Net
I don't recall a timeline, but following Reg. B's timing will suffice. Usually you can do that on the spot and timing shouldn't be an issue.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

Return to Top

Moderator:  Andy_Z, Lucy Griffin, Mary Beth Guard