OCC / FCRA – 17. Does this apply to the regular exchange of information among correspondent banks, between a holding company and its subsidiaries, or among subsidiaries of a holding company?

Compliance > FCRA
Q:  Does this apply to the regular exchange of information among correspondent banks, between a holding company and its subsidiaries, or among subsidiaries of a holding company?
 
A:  Yes. However, a branch or department of a bank may furnish information to another branch or department of that bank without becoming a consumer reporting agency.
 
 
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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