TopMortgage Compliance Update (1)
September 13, 2010
FTC: Seeks Comments on Revised Disclosures

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Overview
On August 27, 2010, the Federal Trade Commission (FTC) published for public comment revised versions of three documents required by the Fair Credit Reporting Act (FCRA). The FCRA requires the FTC to prescribe the content of notices that consumer reporting agencies must provide to those who furnish information to them and to those who obtain consumer reports from them.

The proposed revisions incorporate changes in rights and obligations created by several new rules issued pursuant to the Fair and Accurate Credit Transactions Act of 2003 (FACTA).

Under the FCRA, consumer reporting agencies (CRAs) are required to include a summary of consumer rights with every consumer report they provide to a consumer, and the FTC is required to provide a model summary of rights to be used for this purpose.


Highlights
Revisions and Updates

GENERAL SUMMARY OF CONSUMER RIGHTS
"Your Rights Under the Fair Credit Reporting Act"
  • Furnisher Direct Dispute Rule: which took effect on July 1, 2010, allows consumers to dispute the accuracy of information in their consumer report directly with the furnisher of that information as well as the CRA. The proposed revised Summary of Rights reflects this additional dispute right, and also directs consumers to the FTC's website for more information about disputing consumer report errors.
  • Federal Agency Contacts: the current Summary of Rights incorporates a list of Federal agencies responsible for enforcing the FCRA. The proposed revised Summary of Rights makes this information available on its website in a separate document that lists the Federal agencies responsible for enforcing the FCRA, along with their addresses, phone numbers, and website addresses, which can be updated more easily.
  • Format changes: include revisions to improve the clarity and readability of the document.
NOTICE OF FURNISHER RESPONSIBILITIES
"NOTICE TO FURNISHERS OF INFORMATION TO CONSUMER REPORTING AGENCIES: YOUR OBLIGATIONS UNDER THE FAIR CREDIT REPORTING ACT"
  • Furnisher Direct Dispute Rule: reflects the new duties of furnishers provided in the Summary of Rights.
  • Furnisher Accuracy Rule: new duties contained in the Furnisher Accuracy Rule, which became effective on July 1, 2010, are outlined.
  • Format changes: include revisions to improve the clarity and readability of the document.
NOTICE OF USER RESPONSIBILITIES
"NOTICE TO USERS OF CONSUMER REPORTS: YOUR OBLIGATIONS UNDER THE FAIR CREDIT REPORTING ACT"
  • Risk-Base Pricing Rule: effective January 1, 2011, the Risk-Based Pricing Rule requires users of consumer reports to provide risk-based pricing notices in certain circumstances or permits such users to provide consumers who apply for credit with a free credit score and information about their credit score.
  • Address Discrepancy Rule: effective on January 1, 2008, requires the user to implement reasonable procedures to verify that the consumer report relates to the correct consumer.
  • Medical Information Rule: effective on April 1, 2006, prescribes the circumstances under which creditors may obtain, use, and share medical information.
  • Format changes: include revisions to improve the clarity and readability of the document.
Visit Library for IssuanceLibrary
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FTC: Summary of Rights and Notices of Duties Under the Fair Credit Reporting Act, Federal Register, Vol. 75, No. 166, p 52655
August 27, 2010


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