|
|
|
 |
Compliance Gurus
Lending Gurus
Security Gurus
Marketing Gurus
Technology Gurus
eBanking Gurus
|
FACT Act Negative Notice Disclosure
John Burnett, BOL Guru
Guru BIOS
Question: Our Loan processor has added the capability to print out the FACT Act Negative Notice Disclosure with the new loan paperwork. The Negative Notice is a separate document. My concern is the Notice would be considered being included in the initial disclosures. I understand that the Negative Notice could not be provided with the initial disclosures under the Truth in Lending Act.
Answer: The FCRA prohibits including the Negative Report Disclosure in the disclosures under TILA §127(a), which are the basic open end credit disclosures. So just be certain not to include the FCRA disclosure in those disclosures themselves. You should still be able to provide the FCRA § 623(a)(7) Negative Information disclosure, albeit in a separate document, when granting open end credit.
[Author's note: This answer was updated upon receipt of a comment, for which I thank an alert BOL reader.]
First published on BankersOnline.com 07/04/05; updated 08/15/05
Home | Compliance | Lending | Operations | Security | Marketing | Technology | eBanking
BOL Archives Privacy Policy Important Disclaimer Recommend This Site ! Contact Us
BankersOnline is a free service made possible by the generous support of our
advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all
banking professionals. Support our advertisers and sponsors by clicking
through to learn more about their products and services.
|
|
|
Print Friendly!
Email This Article!
Discuss NOW!