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#161558 - 02/18/04 09:33 PM FCRA and privacy with respect to a deposit account
Anonymous
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We a consumer account with an owner and an additional person listed on the account as an authorized signer.

We recently received negative information on an authorized signer of the account from a consumer-reporting agency.

Under normal circumstances the account would not have been opened if the information were received in advance.

In this instance our policy is to remove the customer (or signer) with which the negative information was received and send a notice of taken notice to the person affected.

My question is this, how do we (or can we) notify the owner of the personal account about the removal of the additional signer without violating the authorized signers right to financial privacy?

Thanks.

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#161559 - 02/19/04 09:04 AM Re: FCRA and privacy with respect to a deposit account
Andy_Z Offline
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Andy_Z
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First, borrowing from Reg. B, I don't believe the convenience signer has an expectation of privacy especially if they were aware this type of verification would happen. Second, you could notify the CS as to why and simply tell the owner the CS has been removed and that the CS has been advised of the reason. Let them talk it out.
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