We have a situation where a mother came in to open joint savings accounts with her two children. She was denied due to NSF activtiy. We of course are sending a notice to the mother, but do we need to send seperate notices to the the children who happen to be minors?

Both of the children were ran through chexsystems and were accepted. So, being that we checked that I didn't know if it made a difference as to sending the notice to them or not. Is there some where in the Reg that addresses this issue? Maybe I just missed something. Any information would be helpful.

The FCRA notice is sent so that if there is a report to dispute, they will know about it. That isn't the case with the kids as their reports were clean. No notice is required for them.

A similar question was asked and is in the InfoVault.

What if you have a situation where a boyfriend and girlfriend want to open a joint checking account and the girlfriend doesn't qualify? We would still be sending the boyfriend a notice stating that the "girlfriend doens't qualify" and a notice to the girlfriend stating the her reason for denial. Isn't that sort of the same situation?

Refusing to open a checking account does not require the Reg B adverse action notice, since no "credit" is involved. The only "adverse action" notice required when you refuse to open a checking account is the FCRA adverse action notice, which is required ONLY when information contained in a consumer report, as that is defined under FCRA, is the reason for the adverse action, i.e., the refusal to open the account, and the notice must go to the person whose consumer report was the reason for the adverse action. Here, the only FCRA notice required would be to the girlfriend. Of course you want to tell the other applicant why you refuse to open the account, but the FCRA adverse action is not required to the boyfriend.

"We'd be happy to open an account for you. But please do not ask us to make it joint with Ms. X, because we cannot accommodate such a request. We'll provide more information to Ms. X."

I'd avoid mentioning the Chex Systems report to the boyfriend. Let him connect the dots himself.