OCC / FCRA – 14. Must disclosures be made if one bank department obtains information on the consumer from another department at the same bank as to its prior transactions or and denies credit based on this information?

Compliance > FCRA
Q:  Must disclosures be made if one bank department or branch obtains information on the consumer from another department or branch of the same bank as to its prior transactions or experiences, and denies credit or increases the charge based on this information?
 
A:  No. Disclosures are required only when information is obtained from an outside source. However, disclosures must be made if the department or branch transmitting the information relays information obtained from third parties outside the bank, and the bank either denies or increases the cost of credit based upon the information.
 
 
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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