Do you reuse credit reports?

Do you have a policy of reusing credit reports?  You may want to re-evaluate that practice, given the growing regulatory and potential legal concerns in this area.  For example, reusing a previous credit report could potentially impact your Ability to Repay calculation if you don’t have current credit information.   Also, credit scores could be inaccurate and fraud alerts could be missed.  Add to that, the Military Lending Act, where the safe harbor has specific timing requirements.  And one other consideration – your contract with the consumer reporting agency may prohibit the reuse of credit reports. 

 

If you’re looking to stay on top of regulatory hot spots or just a refresher on the provisions of the FCRA and FACT Act, join us for our FCRA / FACT Act webinar on September 19, 2017.

 

Published
2017/09/12
Deb Irving

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.

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