Fair Credit Policy Manual

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) provides authority to the Consumer Financial Protection Bureau to "prevent financial harm to consumers while promoting good practices that benefit them." The CFPB has authority under Dodd-Frank to supervise mortgage companies and consumer reporting companies. One of the CFPB strategies to accomplish this goal is to enforce compliance with federal consumer financial laws and prevent unlawful discrimination.

Overview

Are you responsible for ensuring your company's compliance with consumer protection and fair credit laws? Look no further than AllRegs latest policy release, the Fair Credit Policy Manual. This policy reviews the requirements under Regulation V, the Fair Credit Reporting Act. The Fair and Accurate Transactions Act (FACTA) amendments to FCRA as well as those addressed in Title X Section 1088 of Dodd-Frank have been fully integrated into the policy. This manual is designed to aid mortgage brokers, lenders, and servicers in the implementation of fair credit policies relating to confidentiality, accuracy, and utilization of consumer reports; the furnishing of information to consumer reporting agencies; requirements for model disclosure to consumers, and affiliate marketing.

Mortgage bankers/brokers/lenders and servicers have certain duties as users of consumer credit reports and as furnishers of credit information to consumer reporting agencies. AllRegs integrated Fair Credit Policy Manual outlines the responsibilities with which mortgage industry participants must comply.



Benefits

AllRegs Fair Credit Policy Manual offers the following benefits:

  • Recognizes federal regulations surrounding consumer protection laws and highlights the risks associated with noncompliance
  • Reviews permissible purposes in obtaining a consumer report
  • Identifies lender/servicer responsibilities for:
    • Furnishing information to consumer reporting agencies (CRAs)
    • Managing disputed credit information, address discrepancies, risk based pricing notices, and other disclosures
    • Addressing fraud alerts and active duty alerts
  • Provides oversight for managing red flags and an Identity Theft Program

Even better, this plan includes:

  • Complete Fair Credit Policy Manual, saving you development time and resources
  • This manual is delivered via email within one business day after purchase
  • Formatted in an Adobe document
  • Meet your regulatory or internal compliance requirements
  • Affordable one-time purchase fees

Optional Services

Maintenance: Receive regular and ongoing industry updates to keep your policy within regulatory requirements.

Publishing: Publish your manual, including your company procedures, in AllRegs Online to complete your policy manual solution.

Contact your account manager for information regarding these optional services!


Policy Manual
Fair Credit
Section Title Priority Action
1.1 Goals and Objectives Mandatory Review Include the point of view or culture of your organization in this section, if applicable.
1.2 Required Review Mandatory Review Be sure this accurately reflects your company’s annual policy review process.
2.1 Internal Controls Mandatory Review Include or reference related procedures in this section.
3 Staff and Training Mandatory Review Include the means by which your organization provides and tracks required training.
4.4 Prescreened Credit or Insurance Solicitations Recommended Best Practice If not applicable to your organization, you should delete this section
4.5 Responsibilities of Furnishers of Information Optional Enhancement This section includes the protocols to follow when reporting consumer data to a consumer reporting agency (CRA). Consider if you need to augment this list.
4.8 Risk-Based Pricing Notice Mandatory Review Model forms are included here as prescribed by the CFPB. If you use forms that differ from these models, you should include those here.
4.12 Identity Theft Program Optional Enhancement Your Compliance Officer is noted as responsible to supervise and oversee an Identity Theft Program. If your organization has charged a different job position with this duty, you should modify that here.
4.14 Address Discrepancies Recommended Best Practice This section has procedural requirements to revalidate and report an address discrepancy for the consumer upon receipt of a notification from the CRA. Consider if this reflects your actual procedure and modify as needed.