Question: If the bank does not use any type of credit report when denying deposit accounts, are we required to provide an adverse action notice?
Answer: If the bank did not use any type of credit report to deny the deposit account application, then an adverse action notice would not be required under the Fair Credit Opportunity Act or under Regulation B, assuming no extension of credit is involved. However, it’s important to consider that notice may still be required under the bank’s internal policy, so the bank would want to check there as well and be consistent with what it has done in similar situations in the past.
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