Compliance Blog

Written by JiJi Bahhur, Regulatory Compliance Counsel

***

Quick Update - The deadline for NCUA's Loan Participation final rule has been extended to September 23, 2013. NAFCU's Compliance Calendar has already been updated to reflect the new date.

*** 

In Wednesday’s blog post, Bernadette mentioned the release of the Second Quarter 2013 issue of the Philadelphia Federal Reserve’s Consumer Compliance Outlook.  Today, I’ll take a closer look at one of the articles – Adverse Action Notice Requirements Under the ECOA and the FCRA.  The article provides astonishing clarity – as to what requirements apply to the ECOA and what requirements apply to the FCRA – by providing numerous tables breaking down these categories:

• Table 1: When Adverse Action Notices are Required
• Table 2: Who Must Receive Adverse Action Notices
• Table 3: Timing Requirements for Adverse Action Notices
• Table 4: Content Requirements for Adverse Action Notices

I’ve provided a screen shot of the first table – When Adverse Action Notices are Required – but if you have a few spare moments, take a look at the rest of them (or pass the article on to the person at your credit union who is responsible for adverse action notices):

Why is this so important? As the article explains, “To ensure compliance, it is important to understand how the requirements of Regulation B [ECOA] and the FCRA relate to and differ from one another.”  And that’s exactly what this article does: it explains that there are two laws that require adverse action notices; it reviews the adverse action requirements of both the ECOA and the FCRA; and it provides tables to further illustrate the requirements. 

***

If your weekend hasn’t already started, have a great one!  I’m not sure what my weekend will consist of yet, but one thing’s for sure: I can’t wait to spend it with these bundles of joy!