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Pulling ChexSystems Reports on Old Customers

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Question: 
We have recently implemented ChexSystems for new account openings. Are there any disclosures or notifications we would need to provide to existing customers if we would like to go back and pull reports on them? Is this permissable?
Answer: 

I guess the question is why you would do this? It seems like a huge expense. Are you planning to close accounts if you get hits on Chexsystems? If you have performance terms built into your deposit account agreement, you might be able to do it under: otherwise has a legitimate business need for the information (ii) to review an account to determine whether the consumer continues to meet the terms of the account. Without specific terms to meet, I would say that you might have a hard time proving a permitted purpose to pull a credit report.

First published on BankersOnline.com 11/15/10

First published on 11/15/2010

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