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AA Required if Bank Force Closes Checking Acct?

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Question: 
Is an adverse action required to send to a customer if the bank force closes the customer's checking account?
Answer: 

Only if the decision to close the account was based on information from a consumer reporting agency (which include providers such as ChexSystems). Under that circumstance, Sec 615(a) of the Fair Credit Reporting Act would require notice. As long as the information from the consumer reporting agency does not include a credit score, then the notice can be oral, but must include the elements in 615(a)(3) and (4).

First published on 07/22/2018

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