WASHINGTON (5/15/13)--The Fair Credit Reporting Act's (FCRA) treatment of credit report information-sharing rights and adverse action notices are two topics taken on in the May edition of Credit Union Magazine's Compliance Q&A Column.
First, credit reports: As explained by Credit Union National Association Senior Director of Compliance Analysis Valerie Moss in the column, section 1681e of FCRA permits a credit union to disclose the contents of a member's credit report to that member if a loan denial or other adverse action is based in whole or in part on information in the report.
Credit unions should check their credit reporting bureau contracts to see if it is permissible to provide their members with actual copies of their credit reports, Moss recommended.
The FCRA does not require adverse action notices to be released in written form. When a financial institution takes adverse action with respect to a consumer based--in whole or in part--on any information contained in a credit report, the financial institution shall provide an oral, written, or electronic notice of the adverse action to the consumer, Moss explained.
On the other hand, she noted, Regulation B [the Equal Credit Opportunity Act] requires adverse action notices to be in writing for consumer credit. "The term 'in writing' includes electronic delivery of the notice if provided in compliance with the federal ESIGN statute. But, you may give the notifications for business credit verbally or in writing," Moss wrote.
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