Question: Since there are no record retention requirements and/or no signature requirements for several of the required FCRA & FACTA notices, how do we prove compliance to examiners?
Answer: You will need to demonstrate your process for providing the applicable notices. You might have a loan checklist to show the notice was given or maybe the notice is generated by your software and you provide it to the customer at that time. Examiners are going to want to see your system and how it works. There are many ways to do this. Additionally, make sure you train your team so they can answer questions in the event they are interviewed by examiners.
Published
2019/08/23