Posted By: Banker Chick
Credit offer @ DDA open: non-consumer initiated - 08/06/13 03:07 PM
Question:
How are banks handling a cross-sell or firm offer of a credit product at DDA account opening that is not consumer initiated? Obvioulsly, if using a credit score at DDA open, the Bank is prohibited from using that same score to offer a credit product without being in violation of FCRA permissable purpose requirements.
So, my thinking is that a Pre-screening process is the only answer to the delima. I am just getting hung up on how other institutions are doing a proper pre-screening process at DDA account opening to offer a credit product that also complies with the FFIEC policy statement for prescreening.
Any ideas, vendors, or solutions?
Any input is appreciated.
Thanks,
How are banks handling a cross-sell or firm offer of a credit product at DDA account opening that is not consumer initiated? Obvioulsly, if using a credit score at DDA open, the Bank is prohibited from using that same score to offer a credit product without being in violation of FCRA permissable purpose requirements.
So, my thinking is that a Pre-screening process is the only answer to the delima. I am just getting hung up on how other institutions are doing a proper pre-screening process at DDA account opening to offer a credit product that also complies with the FFIEC policy statement for prescreening.
Any ideas, vendors, or solutions?
Any input is appreciated.
Thanks,