Adverse action for denial of ATM or debit cards?

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Question:

Our internal auditor states that we should be sending a Notice of Adverse Action for denied ATM and debit cards. Is this a requirement of the Fair Credit Reporting Act?

Answer:

Not being a credit product, a Reg. B adverse action is not needed. IF a credit line were to be attached, you'd issue the notice related to that credit, not the card.

If you deny the card because of information from a credit reporting agency (incl. ChexSystems), then an FCRA notice is required. This is likely what they are driving at.

First published on BankersOnline.com 07/07/03