Compliance Question of the Week

We had to reduce the credit line on a member’s HELOC because the value of the collateral has significantly dropped. What notice should I send to the member about this?

Compliance Question of the Week

Do we have to send an adverse action notice when we terminate a credit card account due to delinquency?

Risk Based Pricing and Adverse Action Notice Changes Finalized

The Fed and 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 certain information to consumers.

Credit Scores to be Required on Adverse Action and Risk Based Pricing Notices

The proposed rules from the Fed and the FTC will come into effective on July 21, 2011, as part of the credit score disclosure requirements in the Dodd-Frank Act.