The bank has given employees notification via the Employment Handbook that "at the Bank's discretion it will periodically obtain a credit report on its employees", and each employees is required to sign an acknowledgment that they received, read and understand the bank's policy. My question is that if the bank does pull reports on all their employees on a periodic basis, are they violating FCRA by not obtaining a written consent from the employees each time they pull a report. AND shouldn't the statement above include the consumer's rights.

604(b) of the FCRA requires a clear and conspicuious notice to the employee. This is generally accepted as a stand alone notice. Your brief description of the scenario doesn't insinuate that this is the case. That should be corrected.

A notice that says we will access your credit bureau report can specify "this time", or "throughout your period of employment". But annual reminders in conjuncion with ethics updates are a good practice.

Thanks Andy. I have recommended a continuing acknowledgement as recommended by Kirchman so there is no question because I don't think the statement in the Handbook is "clear and conspicuous".