Lining Up FACT Act Players

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Lining Up FACT Act Players

The FACT Act requirements are rolling into place. By this time next year, everything will be final. Between now and then, you need to be on your toes watching for rules as different agencies fulfill their rulemaking assignments.

Implementing the FACT Act may be more challenging than with most consumer protection regulations because it has broad impact throughout the institution. For example, when implementing Regulation CC and Regulation DD, we were working with the deposit-side staff. Most of the attention went to customer service and operations with some attention given to marketing.

The FACT Act will hit everywhere in the institution. No-one will be unaffected. Arguably even the cleaning staff should be aware of information protection procedures. Anyone who uses a credit report will be involved in the implementation. And remember that credit reports include the fraud alerts that your customer service staff obtains before opening a deposit account. There will be changes in how to read and use credit reports.

Then there are the provisions that deal with information reporting and investigations, account number truncation, and affiliate information sharing. The list is incredible. To help you plan and implement, the chart below indicates general areas that are affected with new responsibilities. This list only strikes the surface and we do not represent it as complete. But we hope it will give you a jump-start in working on your FACT Act program

Function	Responsibilities
Loan Officers	Identity theft or fraud alert procedures Active duty notices Credit Score notices Risk-based decision notices
Loan Administrative Assistant	Identity theft or fraud alert procedures Active duty notices Credit Score notices Risk-based decision notices
Credit Analyst	Identity theft or fraud alert procedures Active duty notices Credit Score notices Risk-based decision notices
Loan Administration Staff	Identity theft or fraud alert procedures Active duty notices Adverse credit information reporting
Customer Service Representatives	Consumer information on identity theft prevention and correction Identity theft or fraud alert procedures Active duty notices
Tellers	Consumer information on identity theft prevention and correction Identity theft or fraud alert procedures Active duty notices Complaint procedures
Customer Service Operations	Consumer information on identity theft prevention and correction Identity theft or fraud alert procedures Active duty notices Investigations Identifying and preventing intrusions Account number truncation Providing information to victims of identity theft Disposal of credit report information
Marketing/Business Development	Information sharing Enhanced privacy protections General knowledge for marketing purposes
Executive Assistant	Consumer information on identity theft prevention and correction Responding to complaints Identity theft or fraud alert proceduresActive duty notices
Accounting and Operations	Identity theft or fraud alert procedures Active duty notices Investigations Identifying and preventing intrusions Account number truncationProviding information to victims of identity theft Disposal of credit report information
Human Resources	New performance evaluation requirements New information in credit reports

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