Answer:
You may access a credit report when you have a legitimate business purpose. With today's emphasis on knowing who your customer is, you could justify any deposit account whether it be savings, time or DDA. While each of these has monetary risks, those risks are separate and distinct from KYC/CIP risks. Some credit reports include OFAC checking and that certainly is OK.
Bottom line, if you want to justify the costs, you can do it. If you deny an account because of this, remember your FCRA notice.
First published on BankersOnline.com 11/4/02