Description:
It’s no exaggeration, the regulations implementing the FCRA and FACTA represent some of the most underrated rules in banking. Their reach extends far and wide within financial institutions, covering everything from deposit accounts to loans; Human Resources to Marketing.
Is your Compliance Management System adequately addressing all the numerous facets of FCRA? Gaps are likely to occur simply because so many bank players need to be involved. If you only have an FCRA lending policy, you are undoubtedly leaving off about half the coverage of FCRA. This is most assuredly one of those rules where you might not even know what you are missing.
The FCRA / FACTA imposes a huge number of requirements on users and furnishers of consumer credit reports. This might sound straightforward, but the devil is in the details. Not only do “consumer reports” mean more than you think, but you might be surprised to learn what it means to both “use” and “furnish” them.
Tune in to the upcoming FCRA / FACTA webinar to ensure you have a firm understanding of all these areas:
Lending Issues:
- Permissible purpose
- When medical information may be considered (but should it?)
- Accurate adverse action notice disclosures (far more to them than just Reg B)
- Risk Based Pricing Notices
- Credit score disclosures (several varieties)
- Fraud alerts
- Accurate credit reporting (i.e. lenders can’t waive bad reporting for good customers)
- Furnishing of negative information
- Dispute and error resolution
- Prescreening solicitations (which may impact your customers even if your institution isn’t doing them… Hello “trigger leads”!)
Deposit / Operational Issues:
- Permissible purpose (yep, again)
- Affiliate information sharing and what it means for marketing
- Deposit account adverse action notice disclosures
- Accurate credit reporting (E-OSCAR)
- Re-pollution of data
- Identity Theft Prevention Program (i.e. Red Flags program)
- Disposal of consumer information
- Prescreening solicitations (yes, here too!)
Employment Issues:
- Permissible purpose (I sense a theme…)
- Employment credit reports (Unique – don’t substitute credit reports pulled on the loan side!)
- Required pre-pull disclosures
- Employment adverse action notice disclosures
Do you have a firm grasp on all these things? Fantastic! Still tune in to hear the latest regulatory opinions and possible actions coming down the pike. Register now to polish your understanding of this crucial regulation, taught by a veteran compliance pro of 25+ years who has been repeatedly examined on these laws and has the perspective & insight to share!
Presenters:
Rebekah Leonard
Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to “make clear, explain, throw light upon”, and describes Rebekah’s desire to illuminate the complexities of compliance with passion and fun. She’s created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she’s covered nearly all of it – customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor’s degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006. She is a BOL Compliance Guru.
September 12, 2024