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Can FI Run A ​C​hexsystems on A Business

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Can a financial institution run ​C​hexsystems on a business? Or do we run ​C​hexsystems on all beneficial owners and signers upon written consent?

Chexsystems' website indicates it provides reports on consumers; i.e. individuals, not business entities. Accordingly, you could submit a query on "John Doe," but not "John Doe, Inc."

When your bank pulls a consumer report on an individual is entirely a matter of bank policy; i.e. there is no legal requirement that you ever pull a consumer report. Under the CIP regulation, such reports can be used as a source of non documentary verification for an individual's name, address, identifying number, and date of birth.

You may legally obtain the report when an individual:
* applies to do business with your bank or
* gives you written permission to pull the report.

Beneficial owners are not applying to do business with your bank. A mere authorized signer on an entity's account is not applying to do business with your bank. In both cases, you need the individual's written permission prior to pulling their consumer report.

Consider whether the result is worth the effort...

First published on 02/04/2018

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