What Employers Need To Know About FCRA Credit Check Requirements
Learn more about the FCRA and credit checks, what company credentialing means, and why hiring a CRA to conduct credit checks is a wise investment for your company.
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Ashley Blonquist
8 min read
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Should you conduct credit background checks on candidates for jobs that involve managing money? Employment credit checks can provide valuable insights, but some jurisdictions restrict their use. When is the right time to check a candidate’s credit?
We explain the pros and cons of conducting credit checks during the interview process.
Employment screening is crucial for any hiring process. But some jobs and industries may require taking an extra step with a credit background check, such as financial services, public service, government, or positions that involve managing or handling money.
It’s important to note, however, that some jurisdictions have restrictions on the use of employment credit checks during the hiring process. Before you start, check with your legal counsel to confirm your company qualifies to use credit checks. But similar to other types of screenings—like a criminal background check—the results can provide important insight about a candidate and their overall qualifications for the job role.
Often, employers who use employment credit checks—31% of employers, according to PBSA—run them after a conditional job offer as part of a comprehensive background check. However, that process may not work for you.
So, when is the right time to check a candidate’s credit in the hiring process? Should the screening take place before an interview, during the interview stage, or after a job offer has already been presented?
GoodHire is sharing the pros and cons, as well as important considerations about using credit checks, so you can make the best decision for your company.
The timing of when you’re allowed to conduct background checks legally may be determined by fair hiring laws in place wherever your company and candidates are located.
While the purpose of ban-the-box laws is to remove the question about criminal history from job applications to give candidates with criminal records an opportunity to secure employment, many ban-the-box and fair chance hiring laws include additional “fair chance” provisions, which includes the timing of when background checks can be run—including credit checks.
Many ban-the-box laws prohibit employers from running a background check prior to a first interview or conditional offer. These laws apply to both your company location and the candidate’s location, even if they’re in different states, counties or cities, so it’s important to check whether a law exists in one or both of those locations, as well as the timing provisions of the laws so you know exactly when a background check is allowed.
There are benefits to running a credit check during the interview process. First, employers and hiring managers may save time vetting candidates’ qualifications as it pertains to managing financial obligations before they get to the interview stage. Doing so may also save additional time by eliminating the need to file extra paperwork or create job offers, only to rescind them later if the results are unfavorable.
Why does this matter? The average cost to hire a new employee is nearly $4,000—which doesn’t include the number of days spent interviewing.
Next, running credit checks earlier can provide employers key information earlier in the hiring process. They can help narrow down more qualified candidates to move forward with and eliminate candidates with unfavorable results that would make them unqualified.
That’s because credit background checks can reveal details like a candidate’s history of handling money, responsibility, and trustworthiness—details which are not readily available through resumes, CVs, and interviews.
There are also downsides to running credit background checks during the interview process—if you’re allowed to do so legally (check for any applicable ban-the-box laws, as we covered above).
First, running credit background checks earlier in the process means screening more candidates who may not stand a strong chance of advancing to additional interviews or potential job offers, which ultimately increases your screening costs.
Next, asking for more sensitive information (such as Social Security numbers) in the beginning stages of the hiring process may be a turn-off for well-qualified candidates. Why? They may not want to supply sensitive information due to the risk of identity theft. Candidates may worry that companies don’t have proper measures in place to protect their personal identifying information from becoming compromised.
What’s more, candidates may not understand why a credit check is needed or what type of information employers will have access to, which can also deter candidates from applying or interviewing. For example, candidates may not understand that a credit background check won’t reveal their credit score. If they don’t have a strong credit score, they may be concerned it will deter their chances of securing the job.
Running a credit check too early may also limit a candidate’s ability to prove their worthiness in other ways, such as the interview process and through professional references checks. After all, some candidates may be struggling with financial hardships due to reasons beyond their control. For example, personal or family health issues, identity theft, or an impact to their finances as a result of the COVID-19 pandemic, among other reasons. If the results of their credit background check are unfavorable, employers may be quicker to dismiss them as unqualified candidates.
Finally, candidates may be unprepared to disclose their credit information early in the hiring process. If they’re dealing with one of the above situations, they may want time to check their own credit and prepare explanations or correct errors ahead of the credit background check.
While there are several pros and cons to consider, companies ultimately need to make a decision that’s unique to their hiring process. First, determine the costs of recruiting and hiring new employees. Then, calculate how much time you can potentially save by running credit checks before, during, and after the interview process.
Next, consult your current employment screening policy, local state and city laws that apply to credit history, and any applicable fair chance or ban-the-box laws to determine how and when you can conduct credit background checks legally.
Similar to ban-the-box laws, at least 10 states have passed laws which prohibit certain employers from running credit reports at all, or limit how and when they may be used to make hiring or other employment decisions.
And no matter your final decision of when to conduct credit background checks, be sure you’re always taking the proper steps in the hiring process as outlined by the FCRA. Regardless of when you conduct a credit check, rescinding a job offer or deciding not to hire a candidate based on the results of any type of background check requires following the adverse action process to ensure compliance with federal laws. All of which require extra time and resources.
With Credit Background Checks from GoodHire, you can leave the screening process to trusted professionals with the highest compliance standards—no matter where candidates are in the interview process. Employment credit checks through GoodHire can help:
The resources provided here are for educational purposes only and do not constitute legal advice. We advise you to consult your own counsel if you have legal questions related to your specific practices and compliance with applicable laws.
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