On June 1, 2012 the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council released revised Interagency Examination Procedures for the Fair Credit Reporting Act. The revised examination procedures reflect recent amendments to the FCRA pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).
The Dodd-Frank Act revised sections 615(a) and 615(h) of the FCRA to require disclosure of credit scores and information relating to credit scores in: (1) adverse action notices if a consumer’s credit score is used iri taking adverse action; and (2) risk-based pricing notices if a consumer’s credit score is used in setting the material terms of credit. These amendments to the FCRA were effective July 21, 2011 .
The revised examination module also reflects amendments to Regulation V that are consistent with the risk-based pricing amendments to the FCRA. Effective August 15, 2011, these amendments revised the content requirements for risk-based pricing notices and added model forms H-6 and H-7 that reflect the credit score disclosure requirements.
With the publication of the revised procedures expect to see increased examiner attention on these topics.
A copy of the procedures is available at: https://www.federalreserve.gov/bankinforeg/caletters/12-5-attachment.pdf.