Our professionals and support staff have extensive experience. |
Chief Compliance Officer
Senior Regulator (federal)
Senior Examiner (state)
Quality Control VP
Forensic Loan Auditor
|On July 6, 2011, the Federal Reserve Board (FRB) and the Federal Trade Commission (FTC) jointly issued final rules (Rules) to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).|
Our previous notifications were on 1-3-11, and 3-2-11.
If a credit score is used in setting material terms of credit or in taking adverse action, the statute requires creditors to disclose credit scores and related information to consumers in notices under the Fair Credit Reporting Act (FCRA).
The Rules amend Regulation V (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 also amend certain model notices in Regulation B (Equal Credit Opportunity), which combine the adverse action notice requirements for Regulation B and the FCRA, to reflect the new credit score disclosure requirements.
The rules under Regulations V and B are effective 30 days after the date of publication in the Federal Register, which is expected soon.
Effective Date: July 21, 2011
|The Rules amend Regulation V (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. |
Section 1100F of the Dodd-Frank Act (Dodd-Frank) amends section 615(h) of the FCRA to require that additional content be disclosed to consumers in risk-based pricing notices; specifically, if a credit score is used in making the credit decision, the creditor must disclose that score and certain information relating to the credit score.
Rulewriting authority for the risk-based pricing provisions of the FCRA, including the amendments prescribed by section 1100F of the Dodd-Frank, will not be vested in the Consumer Financial Protection Bureau until the date that the section 1100F amendments become effective.
|The Rules also amend certain model notices in Regulation B (Equal Credit Opportunity), which combine the adverse action notice requirements for Regulation B and the FCRA, to reflect the new credit score disclosure requirements.|
Section 1100F of the Dodd-Frank Act amends section 615(a) of the FCRA to require creditors to disclose on FCRA adverse action notices a credit score used in taking any adverse action and information relating to that score.
The FRB is issuing revised model adverse action notices substantially as proposed, and revised to the extent necessary for the adverse action model notices in Regulation B to be consistent with the requirements of section 1100F of the Dodd-Frank.
|Click for Library|
FRB: 12 CFR Part 222, Regulation V and
FTC: 16 CFR Parts 640 and 698
Fair Credit Reporting Risk-Based Pricing Regulations
July 6, 2011
FRB: 12 CFR Part 202, Regulation B
Equal Credit Opportunity
July 6, 2011
RETURN TO TOP
Suite of Services and Specializations
Mortgage Compliance Compliance Administration
Defaults and Claims Reviews Forensic Mortgage Audit�
Mortgage Defaults Task Force Mortgage Quality Control
FHA Examinations State and Federal Examinations
Mortgage Due Diligence FNMA|FHLMC|GNMA Applications
Legal Reviews & Remedies Loss Mitigation Compliance
Sarbanes-Oxley Compliance HMDA & CRA Processing
Mortgage Fraud Audit Disaster Recovery Plans
CORE Compliance Matrix� Statutory Licensing
Business Development Information Security Plans
IT & IS Compliance RESPA-AfBAs
|Lenders Compliance Group is the first full-service, mortgage risk management firm in the country, specializing exclusively in mortgage compliance and offering a full suite of hands-on and automated services in residential mortgage banking. |
We are pioneers in outsourcing solutions for mortgage compliance.
This communication is sent to our valued clients and colleagues, who regularly receive our Mortgage Compliance Updates, Compliance Alerts, and Commentaries.
These publications are free to subscribers. Information contained herein is not intended to be and is not a source of legal advice.
� 2006-2011 Lenders Compliance Group, Inc. All Rights Reserved.