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Information in Adverse Action Notifications

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Question: 
We pull a report (not a credit report) prior to opening checking accounts for new clients. This report only contains information on checking account closures, it is not a credit report, nor do we use this report in credit decision. We have recently changed the adverse action from when we refuse to open a checking account because of information contained in this report, but it mirrors the form we give to our loan clients. Where do we find, definitively, what needs to be included in this Adverse Action notification. Again, there is no credit decision, nor is there any credit information contained in the report received.
Answer: 

It is a credit report under the defintion of a credit report under the FCRA. You would owe them the FCRA adverse action notice that tells them that your decision was based wholely or in part on a credit report, etc. and provide the name and address of the credit reporting agency. You do not have to provide the reasons for the denial, that only applies to credit decisions.

First published on BankersOnline.com 11/7/11

First published on 11/07/2011

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