Answer:
Answer by Jim Bedsole:Nothing in FCRA prevents a bank from sharing credit report information internally between departments of the same bank, even when such sharing is for cross-selling purposes.
Answer:
Answer by Randy Carey:One thing that a bank should consider prior to using credit reports in any type of cross-selling/marketing endeavor would be to review the FTC Staff Opinion that is commonly referred to as the Gowen letter. The Gowen letter indicated that the use of a credit report obtained for one purpose, then used for cross-selling/marketing purposes, would not be deemed as used for a permissible purpose. While the cross-selling/marketing of HELOCs to individuals that have recently obtained or applied for a first mortgage loan is a great idea, the bank might be safer to choose to stick with the information that the applicant provided to the bank through the application process rather than referring to anything found in the original credit report.
First published on BankersOnline.com 4/03/06
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