OCC / FCRA – 13. Must a bank make any disclosure to the consumer when it denies credit or increases the charges solely on the basis of its prior transactions or experiences with him or her?

Compliance > FCRA
Q:  Must a bank make any disclosure to the consumer when it denies credit or increases the charges solely on the basis of its prior transactions or experiences with him or her, or unverified information furnished by the consumer on his or her application?
 
A:  No. Disclosure is not required in these circumstances. However, disclosures must be made if credit is denied or the cost increased because of information obtained from third parties when verifying information on the application (16 CFR 603(d)(3)(A)).
 
 
This Q&A was obtained from the Comptroller’s Handbook on Fair Credit Reporting that may be found here:  https://www.occ.gov/publications-and-resources/publications/comptrollers-handbook/files/fair-credit-reporting/index-fair-credit-reporting.html
 

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