Adverse Action at Account Opening: Reporting & Documentation

Most financial institutions believe that the Fair Credit Reporting Act (FCRA) only applies to “credit.” But it also applies to “deposit” accounts if the institution relied on information from a credit reporting agency or a deposit account screening company such as Certegy, ChexSystems, or CrossCheck. Surprised? Under FCRA, financial institutions are required to send adverse action notices when refusing to open a deposit account based on information from a credit reporting agency or a checking account screening company. Further, although the Equal Credit Opportunity Act (ECOA) only relates to “credit,” it does apply if overdraft protection was related to the account. This webinar will explain adverse action reporting and documentation requirements for deposit accounts under both FCRA and ECOA.