Delinquent Credit Reporting
Question: I was assuming that we would have to provide the FACT Act notice about reporting delinquent credit before we report the delinquency. However, I saw something recently that seems to allow later notices. Could you clear this up?
Answer: The new rule (which takes final effect in December) is quite flexible. You must provide the notice within 30 days of reporting the delinquency. You may provide the notice at any earlier time. This leaves you with a lot of choice about compliance procedures.
Some institutions are sending the notice with the delinquency notice to the consumer. Others are providing it before or at consummation. Still others may opt to send a separate notice. All approaches are compliant.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 12, 11/04
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