New Accounts Series: Adverse Action at Account Opening — Reporting & Documentation

Most financial institutions believe that the Fair Credit Reporting Act (FCRA) only applies to “credit.” But it also applies to “deposit” accounts if the institution relied on information from a credit reporting agency or a deposit account screening company such as Certegy, ChexSystems, or CrossCheck. Surprised? Under FCRA, financial institutions are required to send adverse action notices when refusing to open a deposit account based on information from a credit reporting agency or a checking account screening company. Further, although the Equal Credit Opportunity Act (ECOA) only relates to “credit,” it does apply if overdraft protection was related to the account. This webinar will explain adverse action reporting and documentation requirements for deposit accounts under both FCRA and ECOA.


Determine when an adverse action notice is required if your financial institution refuses to open a new deposit account
Explain situations when the FCRA and/or the ECOA apply to deposit accounts
Distinguish between the adverse action notices under the FCRA and under the ECOA
Know how to exempt your financial institution from sending adverse action notices
Create a standard notice to use when your financial institution refuses to open a deposit account


Model FCRA adverse action notice for deposit accounts
Model of combined FCRA and ECOA adverse action notice if overdraft protection is involved
Employee training log
Interactive quiz

This informative session is designed for deposit operations personnel, compliance staff, managers, attorneys, and anyone who opens deposit accounts.

ABOUT THE PRESENTER – Elizabeth Fast, JD & CPA, Spencer Fane LLP
Elizabeth Fast is a partner with Spencer Fane Britt & Browne LLP where she specializes in the representation of financial institutions. Elizabeth is the head of the firm’s training division. She received her law degree from the University of Kansas and her undergraduate degree from Pittsburg State University. In addition, she has a Master of Business Administration degree and she is a Certified Public Accountant. Before joining Spencer Fane, she was General Counsel, Senior Vice President, and Corporate Secretary of a $9 billion bank with more than 130 branches, where she managed all legal, regulatory, and compliance functions.


Live Webinar – $245
Recorded Webinar and Digital Download – $245 plus tax
Live Webinar, Recorded Webinar and Digital Download – $320 plus tax


Oct 26 2021


2:00 pm - 3:30 pm