Deposit Adverse Action

I Want to see if this denial was documented ok.
Sue Smith and Tom Thomas came in to open a checking account. Sue's credit report came back with several collection items, so we provided her with a Notice of Action taken and disclosed the credit bureau company we used to pull the report.
Tom's report came back with no matches. (Since he was born in 1984, I find this a little unusual.) He was provided a seperate Notice of Action taken marked we are unable to approve you request and marked that our decision was based on the credit bureau.
No reason for the action was listed on either notice. Is this acceptable? It is my understanding we do not need to mark reasons for the denial. Is there a problem with having a section called Reason for Action Taken if we do not mark any reasons?

Correct. No reason is required for denial of a deposit account; you are only required (per Fair Credit) to show where you obtained this information.

If there is a section on your form called "reason for action taken" you could mark it "N/A", or you could print a form that didn't have this section.

Thanks Lois for your response.

Do you think an examiner would critize us for leaving the reasons for action taken blank?

If a Notice of Action did not have the box checked that we used information from a credit bureau and did not provide the address and phone number of the credit bureau, would you send it out to the customer even if it was a couple of weeks later?

[quote=ksm]

Do you think an examiner would critize us for leaving the reasons for action taken blank?
[quote]

Answer - No


If a Notice of Action did not have the box checked that we used information from a credit bureau and did not provide the address and phone number of the credit bureau, would you send it out to the customer even if it was a couple of weeks later?


Answer - Yes

Thanks again Lois!!!

Is it required by law to have the name and address of one of our offices on our deposit notice of denials?

I know 202.9 requires this on credit denials.

There is no requirement to give any deposit denial (other than the FCRA notice, if applicable), so there are not requirements to include the name/address of the bank.

TeleCheck or similar companies often provide small pads with the FCRA AANs. If you access one of the major credit bureaus for a product or service like a deposit account, you can create your own FCRA notice in the same small fashion as is provided by the check approval vendor. You may find this is less expensive than using loan type AAN forms, if that is what you're doing.