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FORGET YOUR PASSWORD? Editor: Lucy H. Griffin Board of Advisors: John S. Byrne, Esq. Robert P. Chamness Cliff E. Cook Phillips G. Gay, Jr. Barbara Hurst Richard Insley Michael D. Maher Robert G. Rowe, III Andy Zavoina |  |
Volume 8, Number 15 This issue went to press on January 23, 2004. Table of Contents FACTA and Credit Scores (10 Action Steps) Because consumers (and some lenders) don't understand credit scoring, the use of scores has generated controversy. FACTA has entered the arena. The new act imposes several requirements related to credit scoring. Unfortunately for the lending industry, these requirements are likely to prove the most complex for compliance. Action Training: What is Risk? (Sources and Controls) Risk is today's watchword. We hear it talked about, we use the term, we even pretend to know what we are talking about. But there is a moment when things hit the wall and we have to ask ourselves what this risk stuff is really all about? Compliance Notes
This is one of the more complicated laws to come down in recent years. It affects many participants in the credit industry and creates new responsibilities and new interactions between types of credit-related businesses. No matter how you feel about FACTA, it is clearly going to be the source of more regulatory burden. Compliance Q&A Five questions relating to mortgage broker fees.
As with most laws and regulations, the privacy requirements laid down in Gramm-Leach-Bliley are no exception. No one is thrilled with how the privacy process is going. One of the nettlesome points is the notice itself. Preemption: OCC vs. States The OCC's proposal to preempt state laws that infringe on national bank lending practices has generated heated discussion 
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