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#2189286 - 08/15/18 08:34 PM AAN - Payroll Accounts
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,668
Couldn't find anything definitive about this, but from what I can tell it would be required.

Scenario: Employer sets up a payroll card service for employees. A particular employee is deemed ineligible to get such a card by the Bank that holds the account based on information obtained in a consumer report.

I have a heard of AAN's for deposit accounts, loans (of course), but not ever for payroll card accounts.

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#2189288 - 08/15/18 08:41 PM Re: AAN - Payroll Accounts Compliance NABW
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
There is no mention of a loan in the adverse action notice requirements in Sec 615 of the FCRA:

Sec. 615. Requirements on users of consumer reports

(a) Duties of users taking adverse actions on the basis of information contained in consumer reports. If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall...

So you are selling your payroll card product to employers and then you are going to deny individual employees a card? If I was the business I would leave. These are preloaded cards, are they not.
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