Description
It’s no exaggeration: 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 occur frequently, 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 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 webinar to understand how we got here, and what “here” is: a plethora of rules touching all parts of banking!
Part 1 – Operations and Deposit Account Issues
Don’t let the “credit” in Fair Credit Reporting Act give you the wrong idea. FCRA most assuredly holds context within the deposit, operations, and Human Resources side of the house.
We’ll start with a primer on the creation and purpose of the FCRA, and then move into these specific non-lending-related areas:
Deposit and Operation Issues:
- Permissible purpose
- Prescreening solicitations (a bigger deal than you likely realize)
- 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
Employment Issues:
- Permissible purpose (again!)
- Employment credit reports (Unique – don’t substitute credit reports pulled on the loan side!)
- Required pre-pull disclosures
- Employment adverse action notice disclosures
Part 2 – Loan Account Issues
OK, here we go! Having established foundational facts in Part 1, we’ll take FCRA mastery to the next level in Part II, by diving deep into these specific lending related areas:
- Permissible purpose (I sense a theme…)
- CAN medical information may be considered? – New 2025 CFPB action!
- 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”!)
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!
* Please note that the recording links will be delivered to you via a downloadable PDF in your confirmation e-mail. The PowerPoint that corresponds with the recording will be automatically delivered upon purchasing via email from the website.
