Webinar: Fair Credit Reporting & FACT Act Risk-Based Pricing Notices: Clarifying the Confusion
The Fair and Accurate Credit Transactions Act and the Dodd-Frank Act both amended the Fair Credit Reporting Act, mandating the use of risk-based pricing notices for consumers and requiring disclosure of consumers' actual credit scores and related information if a credit score is used when taking adverse action or setting credit terms. However, there are important exceptions. This webinar will clarify situations where a credit union is required to provide notices and disclose credit scores. Notice timing requirements for consumer credit and specific model notices for each credit type will also be covered. All participants will receive a copy of each model risk-based pricing notice and a guide for using the notices.
About This Session:
This webinar will cover the following topics:
- When to include a credit score in the adverse action notice
- Setting credit terms without using the consumer's credit score
- Proving to examiners that a credit score wasn't considered in making a credit decision
- Working with multiple debtors or multiple credit scores
- What to do if the consumer has no credit score
- Using the credit score of a guarantor or co-signer
Who Should Participate: Loan officers & operations personnel, credit analysts, compliance officers, auditors, attorneys and managers
About the Presenter:
Elizabeth Fast, JD & CPA, Spencer Fane Britt & Browne LLP
Elizabeth Fast, Esq., is a partner with Spencer Fane Britt & Browne LLP, where she specializes in the representation of financial institutions and acts as head of the firm's training division. Before joining Spencer Fane, she was General Counsel, SVP and Corporate Secretary of a $9-billion bank with more than 130 branches, where she managed all legal, regulatory and compliance functions. Fast is a member of the Missouri State Banking Board by appointment of the governor.