Credit unions that use credit reports as part of a Human Resources process (e.g., hiring, promoting, firing) should be aware of new forms that are required for use beginning January 1.
The Consumer Financial Protection Bureau has issued changes to a number of FCRA forms. The most significant one for credit unions is to the “Summary of Your Rights Under the Fair Credit Reporting Act.” This form must go to employees, or applicants, after the credit union has acquired a consumer report, but before it has taken adverse action based on that report. The substance of the recent change is to replace reference to the Federal Trade Commission with reference to the CFPB.
Credit unions that use consumer reports for employment purposes have an assortment of responsibilities under the FCRA regarding everything from acquiring a permissible purpose, to properly disposing of the report after it’s used. Credit unions that use reports for this purpose should be aware of the requirements, and should have a detailed policy and accompanying procedures to ensure compliance.
The Summary of Your Rights is Appendix K. It, along with a copy of the final rule, can be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-11-14/pdf/2012-27581.pdf.