Adverse Action Notices & Credit Score Disclosures
In our June 2011 newsletter, we reminded you about some pending regulatory changes that could take effect on July 21, 2011. This is also the date that the Consumer Financial Protection Bureau (CFPB) takes over rulemaking authority for consumer compliance. One of the mentioned changes were amendments to Regulation B and its model forms to incorporate the adverse action notice provisions required by the Dodd-Frank amendments to the Fair Credit Reporting Act. These amendments will require creditors to disclose the credit score used to taking adverse action and other information relating to the credit score. A proposal was issued in March 2011, and as of yet no final rule has been issued.
While the effective date stated in the proposal is July 21, 2011, we have seen several other proposals which have been delayed and some that will go into effect without a final rule. So, we have been searching for clarity as to what the expected effective date will actually be. We learned today that July 21, 2011, will be the required compliance date. Since there is no final rule, you should use the proposed rule as your guide.
We will provide an update shortly to assist you in your compliance efforts. Stay tuned.
Published
2011/06/15
David Dickinson
David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.
He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.
David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.