09/20/2010
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.
08/09/2010
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.
06/08/2009
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?
03/30/2009
Do we need to send customers a turn down letter if we deny opening a checking account because of information we obtained from ChexSystems?
08/04/2008
When we open a new account, we pull a credit report and verify ChexSystems. Is a signature required for this? We open an account only at the request of a consumer and supply an adverse action form if the account is turned down.
02/04/2008
When we are freezing a line of credit due to delinquency, do we need to send out an adverse action notice?
02/06/2006
When sending an adverse action letter for a joint application, are one or both applicants' credit histories referenced?
05/23/2005
Our bank is getting ready to start imaging loan documents. Where can I get some information about what documents we should keep originals of and not rely on images?
03/07/2005
When a customer is denied a debit card, what kind of notice must he/she receive? At previous banks we used a form similar to an adverse action for loans, but it didn't have as much info on it. Where can I find this info in the regs?
08/01/2004
During the next six to ten months, the FACT Act provisions will continue to take effect.