We use a chexsystems report for underwriting deposit accounts. Unlike loans is it ok to use a low score as the reason for denial? The factors tied to these scores are unclear as to the reason for the low score making it difficult to be more specific.

You are not required to give reasons when denying a deposit account.

My understanding from the ChexSystems guidance provided about adverse action notices, the following is required when denying a deposit service due to a ChexSystems report:

-Qualifile Score
-Score Date
-The four key factors that adversely affected their credit score. This will be five factors if one is the number of inquiries made. These are listed on the report and can be listed on the AAN.

ChexSystems provides adverse action notice samples for use.

So, there is no need to be able to explain the factors if the customer is unsure why they were declined?

I was always taught that it was not up to the bank to explain anything. We fill out the adverse action notice and provide it to the customer. If the customer has any questions, then they need to contact ChexSystems. Contact information is provided on the AAN.

The ChexSystems AAN (score, date, key factors) is a FCRA requirement because you're denying opening the account based on information in a consumer report.

Specific denial reasons are a Reg. B requirement, which does not apply to a deposit account.