Reg B: Do you need to disclose the Bank's name and address to a declined business applicant?
Is it mandatory to give the customer an adverse action notice when turned down for a deposit account? If so, should the agency we collected the info from provide the forms?
When do you have to send out a Adverse Action Notice on Commercial Loans?
I am preparing an adverse action notice for a denied application, but the applicant does not have a score on their credit report.How do I complete the credit score portion of the adverse action notice when there is no score? Can this section be omitted?
What is the regulatory requirement for declining a customer the Bill Pay Service?
We pull a report (not a credit report) prior to opening checking accounts for new clients. This report only contains information on checking account closures, it is not a credit report, nor do we use this report in credit decision. We have recently changed the adverse action from when we refuse to open a checking account because of information contained in this report, but it mirrors the form we give to our loan clients. Where do we find, definitively, what needs to be included in this Adverse Action notification. Again, there is no credit decision, nor is there any credit information contained in the report received.
Are adverse action notices issued when credit card lines of credit are closed for inactivity?
When I pull a ChexSystem report and the customer is on ChexSytems, can I tell him what is showing? I know I have to give that person an adverse action notice if I am asked what is on there.
We have an application for a new checking account. Part of our approval processing involves running a credit report, which is disclosed on our application. This person's credit appears to be fine, but in conversation with the potential customer, we feel that this is someone with whom we do not want to do business. He has admitted to us that he has had problems dealing with just about everyone with whom he has dealt, and has been banned from most business offices in the town in which he lives. I know that we do not have to do business with him, but what adverse action reason is acceptable? His credit is OK. Quite frankly, we think that he's got mental issues.
Our "Pricing Committee" decides on the APY that they want to offer on certain products, so when we plug in the APY on our system it provides us with the Interest Rate. Our internal system calculates the Interest Rate on the APY that was provided for example as .01489, then on our disclosures, we state that the Interest Rate is .01490 (we round it up). Since this is technically an adverse action to our customers based on us disclosing an interest rate of 1.490 on our disclosures and our internal system is set at 1.489, which is off by .01% is this even an issue? I guess what I am wondering is since we allowed a "cushion" on the APY of .05%, are we allowed any type of “cushion” on the interest rate and by how much?