FCRA & Chexsystems--help!

Generally our bank does not report negative information. We also do not obtain credit scores (but we do get credit *reports*). We also use chexsystems to open accounts.

We previously had not reported closed accounts to Chexsystems. Well recently they informed us that part of our agreement with them required us to do so. So, if and when we start doing this, what other obligations do we have under FCRA (or any other reg that I"m missing). Do we have to disclose that anywhere in the initial privacy notice?

Any advice/help is appreciated.

Just curious why you wouldn't report?

Just as you're relying on other financial institutions to report, we are relying on you as well. Otherwise it's worthless.

Your guess is as good as mine--this was a decision made above my level. Probably got a few disputes and decided it wasn't worth dealing with.

Does anyone know if reporting closed accounts to chexsystems would require a negative information sharing notice?

Those silly senior supervisors that have no idea what's happening on the front, end, LOL.

I just hope you don't become the bank that's known for not reporting to CS.

reporting closed accounts to chexsystems would require a negative information sharing notice?

No.

FACT Act Section 217

‘‘(7) NEGATIVE INFORMATION.—
‘‘(A) NOTICE TO CONSUMER REQUIRED.—
‘‘(i) IN GENERAL.—If any financial institution that
extends credit and regularly and in the ordinary course
of business furnishes information to a consumer
reporting agency described in section 603(p) furnishes
negative information to such an agency regarding
credit extended to a customer, the financial institution
shall provide a notice of such furnishing of negative
information, in writing, to the customer.

FCRA 603

(p) Consumer Reporting Agency That Compiles and Maintains Files on Consumers on a Nationwide Basis.— The term “consumer reporting agency that compiles and maintains files on consumers on a nationwide basis” means a consumer reporting agency that regularly engages in the practice of assembling or evaluating, and maintaining, for the purpose of furnishing consumer reports to third parties bearing on a consumer’s credit worthiness,6 credit standing, or credit capacity, each of the following regarding consumers residing nationwide: