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Don’t Forget About the FACT Act While Eating Turkey!

Today is Thanksgiving…and if you are reading this blog today, you must really love compliance!

In a previous blog I had talked about the recent final rule that implemented sections of the FACT Act which changed the credit union’s responsibilities when it comes to receiving a direct credit report dispute from a member.  Those same rules also included new requirements on the accuracy of credit information provided to the consumer reporting agencies.  And like the new dispute rules, you may have missed the fact that they became effective back on July 1, 2010.

Without going into great detail, the new rule requires credit unions to establish and implement “reasonable” written policies and procedures regarding the accuracy and integrity of the information provided to the consumer reporting agencies.  The credit union will also need to review these policies and procedures periodically and update them as necessary to ensure their continued effectiveness.

The new rule also includes an extremely long list of guidelines which the credit union must consider when developing the policies and procedures.  Don’t take these “guidelines” lightly as regulators will likely be utilizing these guidelines when reviewing your policies.  The guidelines can be found in the Federal Registry on page 31527 for state chartered credit unions and on page 31524 for federally chartered credit unions.

One final word of caution…if the tryptophan hasn’t already put you to sleep today, reading the Federal Registry will undoubtedly place you into a coma…so beware!

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