Credit Score Notice w/ AAN (Denying Deposit Accts)

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Question:

In lieu of the risk-based pricing notice, we use the credit score exception notice. It automatically prints every time we pull a credit bureau report. I understand the purpose of the risk-based pricing is for lending, but we also use the credit bureau report to determine if we will open an account. Is it permissible to give this credit score notice with an AAN when denying deposit accounts?

Answer:

Use of the credit score exception notice intended for loans will not satisfy the requirement for a credit score notice with the AAN for deposit accounts. The bank must provide the score in the AAN as stated in the guidance issued by the Federal Reserve.

First published on BankersOnline.com 1/23/12