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iCompBlogi covers share insurance credit score disclosures
WASHINGTON (8/16/11)--Information on terms and conditions, loan rates, member privacy, and other issues must be included in the brochures that are given to new credit union members. However, the Credit Union National Association (CUNA) has noted, details on share insurance coverage are not required to be provided in membership packets. CUNA in a recent CompBlog post noted that while National Credit Union Administration regulations require credit unions to inform members of share insurance coverage, that disclosure may be provided by posting the NCUA’s “Your Insured Funds” brochure or Part 745 of the regulations in branches and offices. Individual copies of National Credit Union Share Insurance Fund details must be provided upon request. CUNA in a recent CompBlog post noted that while National Credit Union Administration regulations require credit unions to inform members of share insurance coverage, that disclosure may be provided by posting the NCUA’s “Your Insured Funds” brochure or Part 745 of the regulations in branches and offices. Individual copies of National Credit Union Share Insurance Fund details are also available by request. Credit Score Disclosures to current members were also covered by CompBlog this month. In a separate blog post, CUNA said that credit unions are required to provide an adverse action notice with credit score information when they deny a member’s loan application based on a credit score, even if they have previously disclosed that members credit scores to them via a credit score exception notice. CUNA clarified that creditors may not use these exception notices in place of adverse action notices, as the two notices satisfy different Fair Credit Reporting Act (FCRA) requirements. Portions of the Dodd-Frank Act require creditors to disclose credit scores and related information to consumers in risk-based pricing (RBP) notices and adverse action notices under the FCRA if a credit score was used in setting the credit terms or in taking adverse action against a consumer. For more of CUNA’s CompBlog, use the resource link.


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