Dodd-Frank Act Increases Disclosure Requirements for Financial Institutions and Other Businesses Which Make Decisions Based on Credit Scores

more+
less-

Dodd-Frank Act Increases Disclosure Requirements for Financial Institutions and Other Businesses Which Make Decisions Based on Credit Scores

On July 15, 2011, the Federal Reserve Board (“the Board”) and the Federal Trade Commission (“FTC”) published final rules in the Federal Register implementing the credit score disclosure requirements contained in Section 1100F of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). If a credit score is used to set material terms of credit or to take any type of adverse action, the Dodd-Frank Act requires disclosure of the credit score and related information to consumers in Fair Credit Reporting Act (“FCRA”) notices. One of the final rules amended certain model notices in the Equal Credit Opportunity Act’s (“ECOA”) Regulation B, combining the adverse action notice requirements for the ECOA and the FCRA to reflect the new credit score disclosure requirements. The other rule, issued jointly with the FTC, amended Regulation V (related to fair credit reporting) to revise the content requirements for risk-based pricing notices and to add related model forms that reflect the new credit score disclosure requirements. The rules were issued before general rulemaking authority under these statutes was transferred to the Consumer Financial Protection Bureau (“CFPB”), which began formal operations on July 21, 2011.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Richik Sarkar, McDonald Hopkins LLC | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.
×
Loading...
×
×