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Adverse Actions and Demand Deposit Accounts in the Wake of Dodd-Frank

Since the Dodd-Frank Act came into effect, we have seen many changes on the lending side of banking regulations, with more to come. But the Act has had its effects on the deposit side as well. This presentation focuses on the institution’s regulatory responsibility in handling demand deposit account opening requests and denials. How do the Fair Credit Reporting Act’s adverse action notice requirements apply to denials for demand deposit accounts? We will discuss score disclosures and examine how Risk Based Pricing Notices and Alternate Credit Score Disclosures apply when a credit feature is offered on the demand deposit account. What tools are available to assist financial institutions in complying with Dodd-Frank and the FCRA for demand deposit accounts and deposit-side operations? We will also examine what alternatives institutions have to denying that potential account holder and “second chance” accounts. A “second chance” account can be tied to consumer financial education, have limited privileges, and can be converted to a traditional checking account after the consumer successfully manages the account for certain periods of time.

What you Will Learn:

  • What the FCRA requires
  • What is a credit score disclosure and a risk score disclosure
  • What Dodd-Frank Act requirements have been added
  • What operational issues may emerge
  • What consumer protection issues may emerge
  • What is a “second chance” account
  • What compliance tools are available to assist
  • What the range of penalties for non-compliance are

Target Audience:

Deposit operations, account opening desk, compliance & audit

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