FTC's FCRA Interpretations; CARD Act Webcast
Written by Steve Van Beek
On July 20, 2011, the Federal Trade Commission released a staff report on the Fair Credit Reporting Act.  The report - "Forty Years of Experience with the Fair Credit Reporting Act" - contains the FTC's section-by-section interpretations of the FCRA. Â
Why did the FTC issue this report now? Â I think the answer lies in the fact that the new CFPB will be responsible for the FCRA going forward. Â While the CFPB may not have the same interpretations as the FTC, this report should be a very valuable resource to understanding some of the complex requirements of the FCRA.
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Also, just a healthy reminder that NAFCU will be hosting an August 10th webcast on the recent Clarifications to the CARD Act. Â Sarah and I will hit on the following issues in the webcast:
- A summary of the recent clarifications to Regulation Z;Â
- A detailed review of the Fed's determination to limit the ability of credit unions to use floor rates on open-end credit products;
- An examination of how a floor rate on an open-end credit product removes the ability to utilize Reg Z's "variable-rate exception;"Â
- An outline of the Fed's expectations of disclosure requirements for preferred rates given to credit union employees;Â
- An explanation of the inability to ask for "household income" on credit card applications;Â
- A discussion of the new requirements for credit unions for tracking past APR rates for purposes of credit card "APR Reviews;" andÂ
- A refresher on change-in-terms and renewal notice requirements for credit card accounts.
And, as always, you will have the ability to ask questions during the webcast. Â You can save $100 off the registration by signing up by August 3rd. Â Â