CIP and Consumer Reports

If I am CIPing a new deposit account customer, and as part of my verification of ID procedures, use tools provided by what are otherwise consumer reporting agencies, am I correct that does not constitute a consumer report?

Depends on the tools you are talking about.

Just verifying their identity, say, against other sources like Social Security Admin data, maybe also an OFAC screen, as examples.

How are you accessing SSA information - they have no public data bases. And an OFAC screen does nothing as far as CIP verification.

Utilizing chexsystems, which I think has access to Soc Sec database of numbers of decedents

ChexSystems is a CRA.

Yes, but is every product they provide a consumer report as defined in FCRA?

I am not aware of them offering products that are not - but I am no longer on that side of the equation.

Look at 603.(d) then look at 604(a)(3)(f)(i).

I'm not sure how you can contend you are not using the information in relation to a business transaction initiated by the consumer.