Risk Based Pricing and Adverse Action Notice Changes Finalized

The Federal Reserve Board (Board) and the Federal Trade Commission (FTC) on Wednesday issued final rules to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. 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).

As you may remember, the Dodd-Frank Act requires Adverse Action and Risk Based Pricing Notices to contain credit score information as of July 21, 2011.  When the Board and FTC proposed rules implementing this law, proposed model forms were included.  The Northwest Credit Union Association (NWCUA) converted the forms to .doc format and made them available in the Resources section of InfoSight. 

The new final rules also contain model forms.  The NWCUA is currently converting the final model forms to word format and will load them into InfoSight by Friday, July 8.  The new model forms are similar to the old forms, with some changes. 

In addition to the new forms, some procedures for notification have changed.  The NWCUA compliance team is currently analyzing the rules and will publish a Compliance Bulletin in the coming days.  These new rules will be effective 30 days after the date of publication in the Federal Register, which is expected soon.

In the mean time, the final rules for Risk Based Pricing Notices and Adverse Action Notices are available on the Federal Reserve Board’s website in .pdf format. 

As always, contact compliance at compliance@nwcua.org or 800.546.4465 if you have further questions. 

Posted in Federal.