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Education

 

Webinar: Fair Credit Reporting & FACT Act Risk-Based Pricing Notices: Clarifying the Confusion

 

Wednesday, March 20, 2013

 

Speaker: Elizabeth Fast, JD & CPA, Spencer Fane Britt & Browne, LLP

 

About the Program
The Fair and Accurate Credit Transactions Act (FACT Act) amended the Fair Credit Reporting Act to mandate the use of risk-based pricing notices for consumers. The Dodd-Frank Act further amended the Fair Credit Reporting Act to require disclosure of consumers’ actual credit scores and related information if a credit score is used when taking adverse action or setting credit terms. As a general rule, a credit union must provide risk-based pricing notices to consumers when the credit union, based on a consumer credit report, either denies credit or extends credit on terms that are materially less favorable than the terms the credit union extends to other consumers.

 

However, there are important exceptions to this general rule and the notice timing requirements vary depending on the specific type of credit. This webinar will clarify situations where the credit union is required to: 1) provide (and is prohibited from providing) these notices and 2) disclose (and is prohibited from disclosing) the consumer’s credit score. This program will clarify notice timing requirements for specific types of consumer credit and review specific model notices for each. Join us to learn the answers to all of your questions on these reporting requirements.

 

HIGHLIGHTS

  • Overview of risk-based pricing requirements, including a comparison between Reg V and Reg B notices
  • If the credit score isn’t used to make or deny a loan, should the credit score be included in the adverse action notice?
  • What if you pull a credit report, but don’t use the consumer’s credit score in setting credit terms?
  • How can you prove to examiners that the credit score wasn’t considered in making the credit decision?
  • Is a risk-based pricing notice required if all consumers are charged the same rate for a specific loan type?
  • What if there are multiple debtors or multiple credit scores are used?
  • What if the consumer has no credit score?
  • Can you use the credit score of a guarantor or co-signer?
  • How do you determine the range of credit scores that must be disclosed in the risk-based pricing notice?

 

 

 



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