If you conduct pre-hire background checks, you know you have to comply with the Fair Credit Reporting Act (FCRA) or risk trouble (called lawsuits). Part of that compliance is providing notice to the applicant if you are going to take an adverse action based on the background check, along with a Summary of Your Rights Under the Fair Credit Reporting Act. Well, without any fanfare (or advance notice), the Consumer Financial Protection Bureau (CFPB) changed that Summary form, and we are all supposed to be using it.

Why you ask? In May 2018, Congress passed the Economic Growth, Regulatory Relief, and Consumer Protection Act. This law was a response to some big time data breaches and requires nationwide consumer protection agencies to provide free “national security freezes,” which was supposed to make it harder for identity thieves to open accounts in the consumer’s name. The law further required that if someone gets the Summary of Your Rights under FCRA or the Summary of Consumer Identity Theft Rights, the consumer would also get a notice about the security freeze. The new form adds the language about the security freeze. So start using it.

Now that you are compliant, if you have any comments or possible revisions to the form, you have until November 19, 2018, to send them to the CFPB.