New development with FCRA-required forms


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With the January 1, 2013 deadline for using the new CFPB model FCRA forms on the horizon, the CFPB apparently took another look at those forms and realized that they contained a few glitches. On November 14, the CFPB published a notice in the Federal Register correcting various typos and technical errors, effective immediately. The forms in question, the Summary of Consumer Identity Theft Rights, Summary of Consumer Rights, Notice of Furnisher Responsibilities, and Notice of User Responsibilities, appear, respectively, in Appendices I, K, M and N of Regulation V, which the CFPB issued back on December 21, 2011.

In the Supplementary Information in the November 14 Federal Register notice, the CFPB states that, the typos and technical errors notwithstanding, until it advises otherwise, it will regard the use of the model forms that were originally published in December “to constitute compliance with the FCRA provisions requiring such forms and will regard those forms to be substantially similar to the corrected forms.” The CFPB further states that it plans to so advise, and to provide ample time to allow for orderly discontinuation of the December forms, when it issues a final rule to restate Regulation V in 2013.

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.

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