Answer:
You are entitled to pull a consumer report when an individual applies to do business with you. You are not required to provide advance notice of such an action, but many banks voluntarily use signage to make the consumer aware of their intent. If Bert is across the desk attempting to open an account with you in the name of "Bert and Ernie" I would say you have an application from Bert and have the right to pull a report on him. Ernie? No.
Keep in mind that an individual who is authorized to sign on an entity account has not applied to do business with you. In that case, you need his or her written permission to pull a consumer report. Ask yourself 1) why the consumer report would be relevant and 2) how you are going to communicate any opinion you may develop that the individual is unsuitable to his employer. This is the banking equivalent of Pandora's Box.
First published on BankersOnline.com 1/7/13
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