Reg B & Reg Cc ???

When opening a new account, are we required to give $100 cash back if the check is local?? Our check cashing policy states we can only give cash back up to the amount of available funds in a deposit account.

What is the latest version of Notice of Action Taken when denying a checking account.Ours is from 4/98 (Bankers Systems) and doesn't give the denial reasons as the loan denials do.Don't we have to give a reason??

A new account is an exception under Reg. CC.
$100 available under §229.10(c)(1)(vii).

I've always trusted Banker's Systems as being up to date on their forms.
(2) Content of notification when adverse action is taken. A notification given to an applicant when adverse action is taken shall be in writing and shall contain a statement of the action taken; the name and address of the creditor; a statement of the provisions of §701(a) of the Act; the name and address of the federal agency that administers compliance with respect to the creditor; and either:

(i) A statement of specific reasons for the action taken; OR

(ii) A disclosure of the applicant's right to a statement of specific reasons within 30 days, if the statement is requested within 60 days of the creditor's notification. The disclosure shall include the name, address, and telephone number of the person or office from which the statement of reasons can be obtained. If the creditor chooses to provide the reasons orally, the creditor shall also disclose the applicant's right to have them confirmed in writing within 30 days of receiving the applicant's written request for confirmation.

If your BS forms are generated from your core processing system and the updates are not current, you will have out of date forms. I think the current Notice of Action Taken has a 2005 date on it (to coincide with some FACT Act requirements).

Does anyone know where I get a sample REG CC Substititue Check notice?

http://www.federalreserve.gov/pubs/check21/consumer_guide.htm

Quote:

---

What is the latest version of Notice of Action Taken when denying a checking account.Ours is from 4/98 (Bankers Systems) and doesn't give the denial reasons as the loan denials do.Don't we have to give a reason??

---

Reg B is the regulation that requires a reason for adverse action. Reg B does not apply if you refuse to open a deposit account. The only time Reg B would be an issue is if you are also denying a line of credit that would be tied to the deposit account.

Since Reg B does not apply when you decline to open a deposit account, only the FCRA notice is required. The FCRA notification only requires that you notify the consumer if you have declined their request based on information from a consumer reporting agency. The FCRA does not require that you provide a reason for declination.