I hope you all enjoyed the holidays. I am sure many of you are trying to slowly get back into the swing of things. So I thought I would take this opportunity to gently nudge you back into compliance by giving you a simple homework assignment. Take a field trip of your branches and review your Adverse Action, Risk Based Pricing Notices and your Credit Card tabular forms to ensure staff is using a compliant version. This is definitely an easy find for your Examiners in 2013 so why not avoid an Examiner Finding.
Adverse Action – If you are over $10 billion in assets your from should now reference the CFPB as the agency that administers ECOA compliance (Effective January 1, 2013). If you are under $10 billion and a Federal Charter your form should reference the NCUA’s Office of Consumer Protection. If you are under $10 billion and a State Charter your form should reference the Federal Trade Commission.
Risk Based Pricing Notice – Your forms should be updated with the change from the Federal Reserve to the CFPB’s website (Effective January 1, 2013). Here is a link to the model forms (Appendix H) if you need a visual.
Credit Card Tabular forms – Finally, review your credit card application and solicitation as well as your credit card account opening forms. These forms should now reference the CFPB and not the Federal Reserve (Effective January 1, 2013). Here is a link to the model forms if you need a reminder of what forms I am referring to. Specifically look at model forms G-10(A) to G-10(C) and G-17(A) to G-17(C).
Have fun on your field trip and Happy New Year!