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How does the CFPB Updated FCRA Model Disclosures effect Lenders?
The changes do not involve Lender disclosure, it is a change to the disclosure requirements made by CRAs (Consumer Reporting Agencies.) Further explanation below:
Regarding changes to disclosure language associated with FCRA 609 consumer disclosure requirements effective 9/21/2018:
These Summary of Rights disclosure changes are part of the requirements of FCRA section 605A(i)(5) requiring a consumer receive the referenced disclosure under
FCRA section 609 (disclosures to consumer.)
This is not part of the
Risk Based Pricing Notice requirements under FACTA
and cannot be included in the automated disclosures issued by Credit Technologies as the Consumer Score Disclosures rules prohibit the inclusion of any other disclosures.
Please Note: This was not written by an attorney and cannot be construed as legal advice. As with all legal and compliance matters, questions should be directed to persons qualified to provide such advice in your venue.
Consumer disclosure version of credit reports generated though our online system contain the updated language.
Interim final rule: Summaries of Rights Under the FCRA (Reg V)
CFPB Press Release - Updated FCRA Model Disclosures
Article ID: 1241
Created: September 18, 2018 at 10:40 AM
Modified: September 18, 2018 at 2:27 PM
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