Answer:
Answer by Randy Carey: If you used a credit report in the denial process, an FCRA adverse action notice would be required. Otherwise there would be no notice required to be given in the applicant.
Answer:
Answer by Jim Bedsole: If you use, directly or indirectly, information in a report from a consumer reporting agency (which could be a credit report, but could also be a report from a company like Chex Systems) an adverse action notice under the Fair Credit Reporting Act would be required. This is not the same model as the notice of action taken form required for credit denials under Reg B.
First published on BankersOnline.com 9/24/07
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