Adverse Action Required for Denied CD App?

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Question:

If a customer applies for an institutional CD and the bank finds the application to be ineligible/incomplete/denied, does an adverse action letter need to be sent for a CD application?

Answer:

An adverse action notice for denying a consumer a deposit account would only be required if that decision was made based on a credit report. In this case it is an FCRA adverse action notice, not under Reg B.

First published on BankersOnline.com 2/18/13