Adverse action notice for credit-based deposits
How do we produce and deliver the adverse action notice when a credit report drives a deposit, with the reasons included and the delivery recorded?
Generate the notice from the decision that triggered it. When the deposit and credit decision uses a consumer report to require a deposit, a larger deposit or to decline service, Callvu classifies the decision as an adverse action under the FCRA and the state's rules, assembles the notice with the required content (the action taken, the consumer reporting agency's name, address and telephone number, the statement that the agency did not make the decision and cannot explain it, the right to a free copy of the report within the period, the right to dispute its accuracy, and the key factors or score disclosure where the rules require them), delivers it in the customer's recorded language and channel within the period, routes a decision whose basis is unclear to the credit desk in the Decision Desk, and records the notice, its content and its delivery against the account in the billing system.
In scopeSimpleCallvu moves: classify, write back
Last updated November 7, 2026.
The problem today
The deposit was based on a credit report, the applicant was never told, and the examiner found four hundred missing notices.
When a utility uses a credit report to decide a deposit, federal law requires a notice telling the consumer what happened, which agency supplied the report, and what rights they have. Utilities that pull reports at scale miss the notice at scale: the decision is in the billing system, the notice is a letter template nobody triggers, and the applicant finds out their report was used when they are denied something else.
The notice has required content and a trigger: an adverse action based in whole or in part on a consumer report. The trigger is in the deposit decision's basis; the content is a template with the agency's details and the consumer's rights; the delivery must reach the consumer in a language and a channel they use. A notice generated from the decision record is a notice that always goes.
The decision that used the report should be the event that sends the notice.
How it runs
From the requestto the system of record.
A deposit or service decision in the deposit and credit decision process records a consumer report as part of its basis. Callvu classifies it and opens the notice.
- Customer or applicant
- Receives the notice in their recorded language and channel, and may request the free report and dispute it.
- Credit desk
- Decides decisions whose basis is unclear in the Decision Desk.
- Callvu
- Classifies, assembles, delivers, routes and records.
Classify the decision
The decision record is read for its basis: a deposit required, a larger deposit, a declined application, or terms less favorable, where a consumer report (a credit report or a score, or a report from a utility exchange) was used in whole or in part; a decision based only on the utility's own payment history or on a letter from another utility is not a consumer report decision and needs no FCRA notice (the tariff's reasons are told through the decision process instead).
Assemble the notice
The notice is assembled from the decision and the report record: the action taken, the agency's name, address and telephone number as on the report, the statements that the agency did not make the decision and cannot explain it and that the consumer may obtain a free copy within the period and dispute the accuracy and completeness, the key factors or the score with its range and factors where the rules require the disclosure, and the utility's contact for questions; the state's additional content (a statement of the specific reasons where the state requires it, the commission's complaint process) is added by the state rule.
Deliver and decide
The notice is delivered in the customer's recorded language and channel (the electronic channel with consent, otherwise paper) within the period the rules set, with the electronic delivery confirmed; a decision whose basis is unclear (a report pulled but a different basis recorded, a dispute about whether the report drove the result), a report with a fraud alert, or a notice that cannot be delivered goes to the credit desk in the Decision Desk with the decision record and only the allowed outcomes (send, send with the corrected basis, or record no notice required with the reason).
Record and write back
The notice, its content, the delivery channel, the date and the confirmation are recorded against the account in the billing system, the system of record for the decision, and the notice log feeds the compliance report that reconciles every report-based decision to a sent notice.
Where it ends: Every decision that used a consumer report produced a notice with the required content, delivered in the customer's language and channel within the period and recorded, and the compliance report shows no gaps. The Decision Trace shows the classification and the content assembled; the Audit Trace shows the decision, the delivery and the confirmation with time.
Runtime enforcement
What is enforcedwhile the work runs.
The regulations preloaded in Callvu Studio and the bank's own policies, applied as steps that run, not lines in a binder. A step that breaks a rule does not run, so a completed run was compliant.
The handoff
Between the front doorand the back office.
The front door
None needed; the customer receives the notice in their recorded language and channel.
The back office
The credit desk decides only unclear bases and delivery failures; compliance reads the reconciliation report.
The Decision Desk
- A decision whose basis is unclear, a report with a fraud alert, or an undeliverable notice goes to the credit desk in the Decision Desk with the decision record and only send, send with the corrected basis, or record no notice required with the reason.
Proof
In scope.Proof at scale, not one process at a time.
The kind of process Callvu runs in production for customers in this industry. Ask for a reference on this exact process. The results below are the industry's published proof; each claim code links to its record on agents.callvu.com.
More than 1,000 processes are live across Callvu customers.
Across Callvu customers
PSEG Long Island runs start, stop and move service on Callvu, live in 4 weeks.
Across Callvu customers
Questions
What buyers ask next,answered plainly.
When is the notice required?
Whenever a consumer report was used in whole or in part to require a deposit, a larger deposit or to decline service; a decision based only on the utility's own history or a letter from another utility needs no FCRA notice.
What must it say?
The action taken, the agency's name, address and telephone number, that the agency did not make the decision and cannot explain it, the right to a free copy within 60 days and to dispute, the score and key factors where used, plus the state's content.
How does the utility know every notice went?
The notice is generated from the decision record and recorded against the account, and the compliance report reconciles every report-based decision to a sent notice.
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