Answer:
Regulation B applies to credit products - so the answer would be no, as neither the regulation nor the commentary addresses the application of adverse action to non-credit products. However, the amended Section 615(a) of the FCRA would apply to any type of adverse action (deposit accounts, insurance, etc.) that is taken based on a credit score. The preamble of the Regulation B regulatory issuance does indicate: “The FCRA therefore applies to adverse action decisions related to credit, but also decisions regarding, for example, a deposit account, insurance product, or employment. Although a credit score may generally be used in making or arranging loans, a credit score may also be used in taking adverse action not related to credit. The Board believes that a person would need to disclose a credit score obtained from a consumer reporting agency as part of the adverse action notice as set forth in section 1100F of the Dodd Frank Act, even if the person used the credit score to take adverse action for a non-lending product. In requiring credit score disclosures, section 1100F does not state that the credit score disclosures are only required for adverse action decisions related to credit.”
First published (and revised) on BankersOnline.com 8/15/11
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