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A follow-up question to the 12/20/19 CMG meeting on Adverse Action notices. If you pull a Deluxe Detect or Chexsystems report on a new checking account and you cannot open the account they applied for, but you offered a second chance checking account (with restrictions and higher fees), would you be required to send an adverse action notice? Assuming you still opened an account, but on less favorable terms.
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The requirements that you’re talking about come the FCRA since we’re talking about a deposit account. The Reg B rules for credit say that if you make a counteroffer amd they accept it is not considered AA; however, the FCRA rules do not state a similar provision in the defintion of AA. Since we’re looking to FCRA, if you are making an offer and it is less favorable than what was requested that would be AA and you would be require to provide the notice.
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