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An existing bank customer has requested, in writing, that the bank obtain his consumer report. Is the bank permitted to obtain the report; must the bank request the report; and may it share it with the customer?

An existing bank customer has requested, in writing, that the bank obtain his consumer report to ensure that the information in the report is accurate. I realize that obtaining a report based on the consumer's written consent is among the Fair Credit Reporting Act's permissible purposes for obtaining a consumer report, but I thought that referred to the consumer making the request directly with the consumer-reporting agency. Is the bank permitted to obtain the report; must the bank request the report; and may it share it with the customer?

The bank may, but is not required to, pull the credit report, as the consumer's written consent gives it a permissible purpose to obtain the report under §604(a)(2). However, Section 607(c) of FCRA requires Consumer Reporting Agencies to allow users of reports to disclose the contents of a report but only requires it in the event the bank uses the report as the basis for adverse action, which is not the situation here. In addition, CRA contracts may limit the bank’s ability to share the report with the customer. (October 2020)

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