Fair Credit Reporting & FACT Act Risk-Based Pricing Notices Webinar
2:00 - 3:30 p.m.
In Your Credit Union
The Fair and Accurate Credit Transactions Act (FACT Act) amended the Fair Credit Reporting Act to mandate the use of risk-based pricing notices for consumers. The Dodd-Frank Act further amended the Fair Credit Reporting Act to require disclosure of consumers’ actual credit scores and related information if a credit score is used when taking adverse action or setting credit terms. As a general rule, a credit union must provide risk-based pricing notices to consumers when the credit union, based on a consumer credit report, either denies credit or extends credit on terms that are materially less favorable than the terms the credit union extends to other consumers. However, there are important exceptions to this general rule and the notice timing requirements vary depending on the specific type of credit. This webinar will clarify situations where the credit union is required to: 1) provide (and is prohibited from providing) these notices and 2) disclose (and is prohibited from disclosing) the consumer’s credit score. This program will clarify notice timing requirements for specific types of consumer credit and review specific model notices for each. Join us to learn the answers to all of your questions on these reporting requirements.
- Overview of risk-based pricing requirements, including a comparison between Reg V and Reg B notices
- If the credit score isn’t used to make or deny a loan, should the credit score be included in the adverse action notice?
- What if you pull a credit report, but don’t use the consumer’s credit score in setting credit terms?
- How can you prove to examiners that the credit score wasn’t considered in making the credit decision?
- Is a risk-based pricing notice required if all consumers are charged the same rate for a specific loan type?
- What if there are multiple debtors or multiple credit scores are used?
- What if the consumer has no credit score?
- Can you use the credit score of a guarantor or co-signer?
- How do you determine the range of credit scores that must be disclosed in the risk-based pricing notice?
- TAKE-AWAY TOOLKIT
- A copy of each model risk-based pricing notice
- A guide for when each model notice should be used
Who Should Attend?
This informative session will benefit consumer lending staff, including loan officers, loan operations personnel, credit analysts, compliance officers, auditors, attorneys, and managers. Attendance verification for CE credits provided upon request.
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. Elizabeth is the head of the firm’s training division. She received her law degree from the University of Kansas and her undergraduate degree from Pittsburg State University. In addition, she has a Master of Business Administration degree and she is a Certified Public Accountant. Before joining Spencer Fane, she was General Counsel, Senior Vice President, and Corporate Secretary of a $9 billion bank with more than 130 branches, where she managed all legal, regulatory, and compliance functions. She is a member of the Missouri State Banking Board by appointment of the Governor.
|Over $7 million
|$7 - 75 million
|Under $7 million
Cancellation Policy: Sorry, no cancellations are allowed after connecting instructions and handout materials are distributed to registrants. Substitutions are welcomed and encouraged.
Please note: The live webinar option allows you to have one telephone connection for the audio portion and one Internet connection (from a single computer terminal) to view online visuals as the presentation is delivered. You may have as many people as you like listen from your office speaker phone.
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