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Time Frame for Closing or Revoking Debit Cards

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We use CHEX system to offer packages of services including debit cards. Lately after offering a debit card to a particular customer, we have received notice from CHEX of recent negative activity. What is our time frame for closing or revoking the newly offered debit card? Since it's based on outside information, I'm thinking a FCRA adverse actions would apply. I'm still confused about if we are able to do this since the original debit card offer was made.

Typically, debit card agreement language gives the issuing the bank the right to cancel the card without notice or without advance notice. Specifically, Reg E (in the commentary to Section 205.8) states that notice is not required (under the regulation) when canceling an access device. You don't need to give a Reg B adverse action notice (credit is not involved), but the shorter FCRA notice should be sent. There is no advance notice requirement there, either.

First published on 8/11/08

First published on 08/11/2008

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