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Under EGRRCPA are there new requirements regarding the FACT Act that banks must meet? Is information about credit freezes supposed to be included in any disclosures to consumers? Thanks!
The changes that I believe you are referring to are in Section 301 of EGRRCPA and are additional requirements for consumer reporting agencies. A consumer reporting agency must provide the Summary of Consumer Rights to a consumer with each written disclosure by the agency to the consumer.
The only thing you might need to verify is, if your HR department pulls consumer reports for employment purposes, ensuring the CRA is providing you as the employer the updated disclosure.
Here’s a link to an article we posted on the changes: https://mycomplianceresource.com/category/egrrcpa/
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