Content of AAN for Deposit Account

Posted By: TeamComply

Content of AAN for Deposit Account - 08/11/21 07:28 PM

So we have some changes coming with regard to our identity verification vendor, previously we used an identity verification product through Experian. We currently use ChexSystems and an identity verification platform (currently Experian soon to be changing) as part of the new deposit account opening screening process. The ChexSystems report does not include any type of score. The new identity verification report includes a "third-party fraud score" (ranging from 0-1).

Our current AAN notice includes information for both ChexSystems and Experian. Obviously, Experian is a credit reporting agency; however our new identity verification platform is not through one of the major credit bureaus. Are we required to include their contact information on the AAN for deposit accounts? And are we required to include score information we obtained from them (regarding the "third-party fraud score")?

Thoughts please and thanks!!
Posted By: rlcarey

Re: Content of AAN for Deposit Account - 08/11/21 07:58 PM

That question cannot be answered unless someone would know whether or not your "identity verification" platform vendor is a credit bureau.
Posted By: John Burnett

Re: Content of AAN for Deposit Account - 08/11/21 07:59 PM

Yes, you need to supply the name, address and phone number of the consumer reporting agency that furnished the report to you

No, you don't need to provide that fraud score. The requirement to provide the credit score doesn't apply to any other kind of score.
Posted By: TeamComply

Re: Content of AAN for Deposit Account - 08/11/21 08:29 PM

Socure is the name of the identity verification platform, which I'm pretty certain isn't a credit bureau.
Posted By: TeamComply

Re: Content of AAN for Deposit Account - 08/11/21 08:30 PM

So we would list contact information for ChexSystems and the identity verification source, Socure on our deposit AANs?
Posted By: rlcarey

Re: Content of AAN for Deposit Account - 08/11/21 08:43 PM

If Socure is not a credit reporting agency, why would you include them on the notice?
Posted By: TeamComply

Re: Content of AAN for Deposit Account - 08/11/21 08:55 PM

So we would only need to include ChexSystem contact information on our AAN and nothing about Socure?

Even though our decision to not open an account may have been due to information within the Socure report we obtained?

Our AAN notice does currently state that our decision was based "in whole or in part on information obtained in a report from the consumer reporting agency listed below" So would the "in whole or in part" language cover us - some information may have been based on ChexSystems and some information from another source (such as Socure)?
Posted By: rlcarey

Re: Content of AAN for Deposit Account - 08/11/21 09:04 PM

If they are not providing you a consumer report, then FCRA Section 615(b) regarding Adverse Action Based on Information Obtained from Third Parties Other than Consumer Reporting Agencies only applies to credit requests.
Posted By: TeamComply

Re: Content of AAN for Deposit Account - 08/11/21 10:01 PM

Ok, but ChexSystems is considered a nationwide specialty consumer reporting agency, so their information should be listed on the AAN for deposit accounts?
Posted By: rlcarey

Re: Content of AAN for Deposit Account - 08/11/21 10:29 PM

Yes, that is correct. ChexSystems is a CRA.