FCRA & Adverse Action

When it comes to taking adverse action, the first thing that usually comes to mind are the notification requirements found in Regulation B (aka the Equal Credit Opportunity Act). However, if a financial institution uses information from a credit report in its decision to take adverse action, additional disclosures are also triggered under The Fair Credit Reporting Act (FCRA). Unlike Regulation B, which only applies to credit products/services, the FCRA requirements apply to both deposit and credit products/services. In other words, if information from a credit report is used in the decision to deny a checking account, there are certain disclosures that must be provided.

Kevin explains more in the video.


 Deposit Operations Training

Published
2024/08/12

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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