If a customer requests to open a small business banking deposit account, does the Bank have to get the customer's consent to pull a Qualifile? Or does the request fall under a reason in Section 604 (a) (3)( F) otherwise has a legitimate business need for the information ?
Posted By: Inspector
Re: FCRA Permissible Purpose - 07/12/21 11:04 PM
What is the pull being used for?
Posted By: rlcarey
Re: FCRA Permissible Purpose - 07/13/21 01:07 PM
Also - define a small business - you mean an actual business entity?
Posted By: corporate audit
Re: FCRA Permissible Purpose - 07/13/21 05:29 PM
A Qualifile is pulled for the business entity, as well as individuals acting on behalf of the business entity, such as the custodian, guardian, rep payee, trustee, and executor/administrator.
Posted By: rlcarey
Re: FCRA Permissible Purpose - 07/13/21 05:38 PM
I was not aware that Qualifile handled business entity files - but regardless, unless the individuals you are running are going to be directly liable on the deposit account, you do not have a permissible purpose and I am not aware that CheckSystems allows you to run a report based on written permission.