Written by Steve Van Beek
On July 20, 2011, the Federal Trade Commission released a staff report on the Fair Credit Reporting Act. The report - "Forty Years of Experience with the Fair Credit Reporting Act" - contains the FTC's section-by-section interpretations of the FCRA.
Why did the FTC issue this report now? I think the answer lies in the fact that the new CFPB will be responsible for the FCRA going forward. While the CFPB may not have the same interpretations as the FTC, this report should be a very valuable resource to understanding some of the complex requirements of the FCRA.
Also, just a healthy reminder that NAFCU will be hosting an August 10th webcast on the recent Clarifications to the CARD Act. Sarah and I will hit on the following issues in the webcast:
- A summary of the recent clarifications to Regulation Z;
- A detailed review of the Fed's determination to limit the ability of credit unions to use floor rates on open-end credit products;
- An examination of how a floor rate on an open-end credit product removes the ability to utilize Reg Z's "variable-rate exception;"
- An outline of the Fed's expectations of disclosure requirements for preferred rates given to credit union employees;
- An explanation of the inability to ask for "household income" on credit card applications;
- A discussion of the new requirements for credit unions for tracking past APR rates for purposes of credit card "APR Reviews;" and
- A refresher on change-in-terms and renewal notice requirements for credit card accounts.
And, as always, you will have the ability to ask questions during the webcast. You can save $100 off the registration by signing up by August 3rd.