We are not aware of any initial disclosures required by the FCRA at the time of an account opening. However, if your bank rejects an online account application based on information in a consumer credit report, the FCRA requires you to send an adverse action notice to the applicant. In such case, you should follow your bank’s adverse action policies and procedures as you would for any other deposit account application, whether received online or otherwise.

For more information, including laws, regulations, regulatory guidance and dozens of IBA Q&As, we recommend reviewing the Account Opening and Online Banking pages on the IBA Compliance Connection^® at GoToIBA.com.

For resources related to our guidance, please see:

• FCRA, 15 USC 1681m(a) (“If any person takes any adverse action with respect to any consumer that is based in whole or in part on any information contained in a consumer report, the person shall (1) provide oral, written, or electronic notice of the adverse action to the consumer . . . .”)

• FCRA, 15 USC 1681a(d) (“The term ‘consumer report’ means any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumer’s eligibility . . . .”)