Adverse Action at Account Opening: Reporting & Documentation
StreamedOct 26, 2021Duration90 minutes
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A deposit account can be opened anytime, right? Not so fast!
Sometimes a financial institution will refuse to open a deposit account because of information obtained from a credit reporting agency or checking account screening company. This fast-paced webinar will describe how to handle such a situation and explain when the FCRA and/or the ECOA come into play.
AFTER THIS WEBINAR YOU’LL BE ABLE TO:
- Determine when an adverse action notice is required if your financial institution refuses to open a new deposit account
- Explain situations when the FCRA and/or the ECOA apply to deposit accounts
- Distinguish between the adverse action notices under the FCRA and under the ECOA
- Know how to exempt your financial institution from sending adverse action notices
- Create a standard notice to use when your financial institution refuses to open a deposit account
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.
WHO SHOULD ATTEND?
This informative session is designed for deposit operations personnel, compliance staff, managers, attorneys, and anyone who opens deposit accounts.
- Model FCRA adverse action notice for deposit accounts
- Model of combined FCRA and ECOA adverse action notice if overdraft protection is involved
- Employee training log
- Interactive quiz
Attendance certificate provided to self-report CE credits.
NOTE: All materials are subject to copyright. Transmission, retransmission, or republishing of any webinar to other institutions or those not employed by your financial institution is prohibited. Print materials may be copied for eligible participants only.
Spencer Fane LLP
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