I am aware our Bank would need to send an Adverse Action notice if we turned down a loan due to lack of meeting the Bank's CIP Policies. But if we refuse to open a deposit account for the same reason (in this case false SS#s and yes it is going to SAR Committee), are we required to send an Adverse Action notice for that "denial"? Title 12CFR 202.2(c) regarding Adverse Action notices seems to be discussing credit/loans only. Would love some thoughts on deposit acct. adverse action requirments as they relate to CIP.

Thanks in advance.

If you used a credit report to make this determination you would have to provide a FCRA adverse action notice. Reg. B does not come into play for deposit accounts.

Thank you for the response. I found a Compliance Guru question on this i printed out way back in 12-1-08 (not sure where I got this). But it referes to Appendix H in the FFIEC Manual regrading when an examiner light ask for a list of customers or potential customers for whom the bank took adverse action, on the basis of CIP. The response in 12-1-08 was from Jim Bedsole and Kathleen Blanchard who felt like the Bank should keep a list of accts. that were declined for lack of CIP OR accts. that were opend but had limitations to them due to lack or insufficent CIP. In this case we declined a new deposit acct. So again, do we need some kind of "list" anytime we refuse a deposit acct. due to lack of CIP?

There is no regulatory requirement for it, but the examiners will typically ask to review such instances. It helps to prove that your CIP program is working as designed.

Understand............document document document.....good grief. Thank you again!