Debit Card Denial Disclosure

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Question:

When a customer is denied a debit card, what kind of notice must he/she receive? At previous banks we used a form similar to an adverse action for loans, but it didn't have as much info on it. Where can I find this info in the regs?

Answer:

The only federal regulation in play is the Fair Credit Reporting Act. It applies if you use a credit report (essentially third-party information) in your decision to deny a product or service.

The loan-type adverse action isn't necessary, but is often used because it allows for an explanation, if you can clearly define it and are not misleading, and mostly because it has the FCRA notice.

First published on BankersOnline.com 3/7/05