New Accounts Series: Adverse Action at Account Opening

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

Tuesday, October 26, 2021 
3:00 pm – 4:30 pm Eastern

A deposit account can be opened anytime, right?  Not so fast!  Sometimes a financial institution will refuse to open a deposit account because of information obtained from a credit reporting agency or checking account screening company.  This fast-paced webinar will describe how to handle such a situation and explain when the FCRA and/or the ECOA come into play.


  • 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


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.


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


  • 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


Elizabeth Fast, JD, CPA
Spencer Fane LLP

Elizabeth Fast is a partner with Spencer Fane 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.  

Attendance verification for CE credits provided upon request.

Webinar Sponsored by Financial Education & Development

If you are having issues with registering online, please contact CBAO's Education, Training & Special Events Coordinator, Patti Webb, (614) 610-1877.

Registration Options (Member/Non-Member Pricing)
Live Webinar ($345/$490) – The live webinar option allows you to have one internet connection from a single computer terminal. You may have as many people as you like listen and watch from your office computer. Registrants receive a website address and passcode that will allow entrance to the seminar. The session will be approximately 90 minutes, including question and answer sessions. Seminar materials, including instructions, passcode, and handouts will be emailed to you prior to the broadcast. You will need the most-current version of Adobe Reader available free at

Recorded Webinar + Free Digital Download ($265/$400)– Can’t attend the live webinar? This option provides a recording of the live event, including audio, visuals, and handouts. We even provide the presenter’s email address for follow-up questions. You will receive an email with the recorded webinar link, which can be viewed anytime 24/7, beginning 6 business days after the webinar. You will also receive instruction on how to download a free digital copy of the webinar to your PC, which you may keep and use indefinitely.

Additional Live Webinar Connections ($175/$260)  – Registering another banker from a different location

Both Live Webinar & Recorded webinar + Free Digital Download ($395/$600)– Includes Live Webinar and Recorded Webinar options above.


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