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.
Published
2024/08/12