Q: What information may a bank give to third parties in response to inquiries about a consumer, without becoming a consumer reporting agency?
A: The bank may relate information solely about its transactions or experiences with the consumer. For example, the bank may disclose that the consumer had a history of delinquency and could give other information about the status of any loans or deposits with it. To ensure that it does not become a consumer reporting agency, it should not regularly issue information:
• Contained in credit applications bearing on the consumer’s creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living.
• Obtained in reports from consumer reporting agencies or any other information obtained from third parties. For example, a bank that obtained information as a user may become a consumer reporting agency if it subsequently conveys the information to another bank.