OCC / FCRA – 15. What actions should a bank consider to ensure its compliance with the requirements imposed on a user of consumer reports?

Compliance > FCRA
Q:  What actions should a bank consider to ensure its compliance with the requirements imposed on a user of consumer reports?
 
A:  The bank should consider: filing the certification mentioned in question 2 with each consumer reporting agency whose services may be used; retaining a file copy; instructing employees that consumer reports may be obtained only for the purposes specified in the act and certification; developing procedures for making required disclosures to consumers when credit, insurance, or employment is denied, or when the cost of credit or insurance is increased, based on information obtained from outside sources; and recording all inquiries to reporting agencies or others, as well as information obtained through those inquiries, so that accurate disclosure can be made to consumers.
 
Forms may be useful for advising the consumer of the name and address of the consumer reporting agency (when a consumer report is involved), or his/her rights to request the nature of the information when other outside sources are involved.
 
 
This Q&A was obtained from the Comptroller’s Handbook on Fair Credit Reporting that may be found here:  https://www.occ.gov/publications-and-resources/publications/comptrollers-handbook/files/fair-credit-reporting/index-fair-credit-reporting.html
 
 

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