Our bank uses ChexSystems when opening deposit accounts, but does NOT pull a Qualifile score. We do provide AAN on deposits, but are exempt from the new credit score disclosures since we don't pull that score. We also report negative information to ChexSystems, but til now we have relied on the fact that they did not meet the definition of a CRA, and therefore we did not need to furnish negative information notices to our customers.
In completing an annual review of policy, we started looking more closely at ChexSystems--now that they COULD be considered a CRA, should we be providing negative information notices?