Topics In This Issue
• Federal Issues
• Firm News
• Consumer Finance
• Criminal Enforcement Action
Excerpt from "Federal Issues"
Federal Reserve Board and Federal Trade Commission Propose Rules Regarding Credit Score Disclosure Requirements. On March 1, the Federal Reserve Board (Board) and Federal Trade Commission (FTC) proposed rules addressing the Dodd-Frank Act requirement that creditors disclose credit scores and related information to consumers in risk-based pricing and adverse action notices. This disclosure is required when a credit score is used in setting credit terms or taking adverse action. The Board and FTC propose amending Regulation V (Fair Credit Reporting) to revise the content requirements for risk-based pricing notices and to add model forms that reflect the new requirements. The Board and FTC note that the change does not affect the existing, alternative "exception notices" used by mortgage lenders and other creditors, in which the creditor provides a credit score and other disclosures to all applicants early in the application process. The Board and FTC also propose amending certain model notices in Regulation B (Equal Credit Opportunity), which combine adverse action notice requirements under Regulation B and the Fair Credit Report Act, to incorporate the new requirement to include a credit score in a FCRA adverse action notice if one was used in taking adverse action. Public comments on both proposed rules are due 30 days after their forthcoming publication in the Federal Register. Click here for a copy of the notice for the proposed rule amending Regulation V; click here for a copy of the notice for the proposed rule amending Regulation B.
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