Written by Michael Coleman, Regulatory Compliance Counsel
Regulation B - Adverse Action Notices
When the CFPB republished Regulation B into 12 CFR 1002, they updated Appendix A to Part 1002 to reflect the address for NCUA’s new Office of Consumer Protection (OCP), which is required to be listed on adverse action notices for credit unions under $10 billion in assets starting January 1, 2013.
The underlying requirement for including the agency address on adverse action notices comes from 12 CFR 1002.9(a)(2) and (b)(1).
Appendix A to Part 1002 now includes this information for FCUs under $10 billion on assets:
"d. Federal Credit Unions: National Credit Union Administration, Office of Consumer Protection (OCP), Division of Consumer Compliance and Outreach (DCCO), 1775 Duke Street, Alexandria, VA 22314."
Credit unions over $10 billion in assets need to include the CFPB's name and address:
“1. Banks, savings associations, and credit unions with total assets of over $10 billion and their affiliates: Bureau of Consumer Financial Protection, 1700 G Street NW., Washington DC 20006. Such affiliates that are not banks, savings associations, or credit unions also should list, in addition to the Bureau: FTC Regional Office for region in which the creditor operates or Federal Trade Commission, Equal Credit Opportunity, Washington, DC 20580.”
State-chartered credit unions should check the address on their notices and determine if it matches the FTC address in #9 from Appendix A.
For additional details, check out this January 13, 2012 blog post
Regulation V - Risk-Based Pricing Notices
Regulation V was also updated when the CFPB republished Regulation V in 12 CFR 1022 and will require the CFPB's website address on risk-based pricing notices after January 1, 2013.
The requirement comes from 12 CFR 1022.73(a)(1)(viii) which mandates that credit unions provide this on their risk-based pricing notices:
"(viii) A statement directing consumers to the Web site of the Bureau to obtain more information about consumer reports;"
After January 1, 2013 - credit unions need to make sure they have the updated language referencing the CFPB. Appendix H to Part 1022 has the model forms where you can see the risk-based pricing notice requirements.
For additional details, check out this June 7, 2012 blog post.
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