Synergy by Association
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT
  • About Synergy
    • Contact Us
    • Board of Directors
    • Synergy Partner Advisory Committee
  • PROGRAM PARTNERS
    • ABA Insurance Services
    • Bank Marketing Center
    • Bankers Alliance
    • Cornerstone Advisors
    • CRA Partners
    • Discover Debit
    • Hagan Hamilton
    • ICBA Securities
    • KeyState Captive Management
    • ODP Business Solutions
    • ServisFirst
    • Shred-it
    • StrategyCorps
    • Vericast
  • ASSOCIATION ALLIANCES
  • PARTNER TOOLKIT

Compliance Alliance Question of the Week

9/18/2019

 
Question:
We are moving to a new ChexSystem benefit whereby the credit score will be provided to us. However, we will not use the score in making the determination to deny an account opening. Since we are not using it, do we have to include the additional credit score disclosures?
 
Answer:
If you did not use a credit score in your decision, then there is no technical need to add include the additional disclosures. However, the issue comes in the form of showing that the bank did not actually use the score. So, if the bank does choose not to utilize the credit score disclosures, then it needs to thoroughly document that fact.
Section 1100F of the Dodd-Frank Act amended the FCRA to include additional disclosure requirements when adverse action is taken because of the consumer’s credit score. ... But if the credit score did not play a role in the decision to take adverse action, these disclosures are not required.
Fed. Res., Consumer Compliance Outlook, Adverse Action Notice Requirements Under the ECOA and the FCRA: https://consumercomplianceoutlook.org/2013/second-quarter/adverse-action-notice-requirements-under-ecoa-fcra/   

Comments are closed.
    Picture

    Archives

    March 2020
    February 2020
    January 2020
    December 2019
    November 2019
    October 2019
    September 2019
    August 2019
    July 2019
    June 2019
    May 2019
    April 2019
    March 2019
    February 2019
    January 2019
    December 2018
    November 2018
    October 2018
    September 2018
    August 2018
    July 2018
    June 2018
    May 2018

    Categories

    All
    Compliance

    RSS Feed

    Compliance Alliance offers a comprehensive suite of compliance management solutions.

    To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com.
Copyright © 2023 Synergy by Association, Inc.  All Rights Reserved.
1149 Court Street NE  |  PO Box 13429  |  Salem, OR 97309  |  (800) 468-8558
Picture