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#1380827 - 04/23/10 07:12 PM Re: Section 312 Fact Act illiniyak
Queen Mum Offline
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OK
Are you talking about the sample policy on BOL?

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#1383737 - 04/29/10 06:03 PM Re: Section 312 Fact Act Queen Mum
YosemiteSamIAm Offline
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Management level policy with underlying procedures O.K., correct? No requirement for Board approval?

I have not yet gotten around to submitting a comprehensive FACT Act policy to the Board at this institution yet due to other more pressing matters. That will come on the heels of getting into compliance by July 1st.
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#1383906 - 04/29/10 08:22 PM Re: Section 312 Fact Act DD Regs
smith Offline
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Nebraska
Originally Posted By: DD Regs
Originally Posted By: Deb G
In order to comply with this we only need the following?:

1) written policy/procedures
2) some type of log for disputes (maybe info worksheet w/dates)
3) form for communicating to customer
4) training for those who deal with disputes

I am feeling a little overwhelmed from just finishing up escrow training and trying to get on to the next fun item (there are so many to choose from).

Please provide any info if I missed anything.


What is the form you refer to in #3?


I have the same question about the form referred to in #3.

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#1384860 - 05/03/10 02:22 PM Re: Section 312 Fact Act smith
#Just Jay Offline
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I assuming they mean a response/follow-up form to the consumers direct dispute, you either say yes or no.
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#1384903 - 05/03/10 03:22 PM Re: Section 312 Fact Act #Just Jay
lucyc Offline
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Can you tell me where it states that Chexsystems will be included as a CRA to comply with these changes?

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#1389802 - 05/12/10 06:01 PM Re: Section 312 Fact Act lucyc
mbernard Offline
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Does anyone have written procedures that they are willing to share? I saw the one on BOL, but I was hoping to get a few more to help me out.

Thanks!

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#1389905 - 05/12/10 07:55 PM Re: Section 312 Fact Act lucyc
Deena Offline
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Originally Posted By: lvc
Can you tell me where it states that Chexsystems will be included as a CRA to comply with these changes?

You have to look at the definition of "consumer reporting agency" in the FCRA. ChexSystems meets that definition.
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#1390051 - 05/12/10 09:55 PM Re: Section 312 Fact Act illiniyak
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Okay....I have serious tired head from all of the FACTA/FCRA mumbo jumbo. One question for those who still have sanity....

Do you think it would be acceptable to combine red flag, identity theft program, items effective July 1st, etc, etc all into one document for board approval?

I have accumulated way too many policies, programs, etc for this convaluted mess.

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#1390095 - 05/12/10 11:52 PM Re: Section 312 Fact Act POWFNB
Dolly Nugent Offline
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I considered that, but then decided against it. That's a lot of information for a board member to have to read.

On our Intranet, I have a section for FCRA. In it I have included separate documents for the policies, procedures and programs named below. I always consider the user. If it's too difficult to find what they are looking for, they end up calling me. By making it easy for them, I hope to preserve some of my precious time!

These are the sections I will have when I am finished:

Accuracy & Integrity Policy
Direct Dispute Procedures
Credit Reporting Agency Dispute Procedures
Reporting Information to Credit Reporting Agencies Procedures

Red Flag Program

and FCRA Procedures that include:

Permissible Uses of Credit Reports
Adverse Action
Alerts/Freezes
Use of Medical Information
Adverse Action

Only the policy and procedures that require board approval are taken to the board.
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#1390369 - 05/13/10 03:31 PM Re: Section 312 Fact Act Dolly Nugent
POWFNB Offline
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Can I ask a question? At the end of the day, should we have a policy statement for 1) FCRA/Fact ACt, 2) Reg Flag, 3) ID Theft and 4) Credit Reporting? Then, have separate procedures for each? Am I missing a any actual policy that would require board approval?

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#1390411 - 05/13/10 03:55 PM Re: Section 312 Fact Act Dolly Nugent
Ted Dreyer Offline
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Dolly: Unless they are already covered under other sections of your list, you might want to also include Affiliate Sharing, Affiliate Marketing and Notice to Home Loan Applicant/Credit Score disclosures.

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#1390468 - 05/13/10 04:22 PM Re: Section 312 Fact Act Ted Dreyer
Dolly Nugent Offline
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Good point Ted. I failed to mention that I have a procedure section for the Credit Score Disclosure. I reference sharing under the FCRA in our Privacy Policy & Procedures.
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#1391975 - 05/17/10 04:25 PM Re: Section 312 Fact Act Dolly Nugent
Jerseygirl Offline
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From ChexSystems:
Tips to Comply with FACTA Accuracy and Integrity of Data Reported to CRAs
Are you ready for the FACTA Accuracy and Integrity of Data Reported to Consumer Reporting Agencies? Section 312 of the Fair and Accurate Credit Transaction Act (FACTA) becomes effective on July 1, 2010. To help you prepare, FIS recommends:
1. Please read the ChexSystems, Inc. (Chex) Data Contribution Policy (DCP) that defines the requirements for furnishing data to ChexSystems, a Consumer Reporting Agency (CRA

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#1396104 - 05/25/10 10:55 PM Re: Section 312 Fact Act illiniyak
ggb Offline
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Other than references made to this on webinar advertisements, I'm not seeing anything in the guidance that specifies what the "required data audit and testing techniques" are under FCRA and FACTA 312. The ads lead me to believe there are very specific steps to be included....any insight, anyone? Thanks.

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#1398214 - 06/01/10 06:43 PM Re: Section 312 Fact Act Dolly Nugent
raitchjay Offline
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Originally Posted By: Dolly Nugent
Appendix E to the regulation includes guidelines for developing your policies and procedures. We are supposed to incorporate those that are appropriate.



Where can i find Appendix E? I'm used to using BOL to look at regulations, and i don't see Appendix E.
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#1398306 - 06/01/10 08:31 PM Re: Section 312 Fact Act illiniyak
Trees Offline
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Do we need a board approved policy statement or can this be rolled into a existing policy, with "robust" procedures, of course?

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#1398330 - 06/01/10 08:53 PM Re: Section 312 Fact Act raitchjay
Dani York, CRCM Offline
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TN
http://www.bankersonline.com/regs/222/e222.html

raitch....you can find this and the rest of the FCRA & FACT Act amendments under Reg V in Alphabet Soup.
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#1398340 - 06/01/10 08:59 PM Re: Section 312 Fact Act Dani York, CRCM
raitchjay Offline
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Dani...thanks.....i was having a major brain cramp. smile
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#1584868 - 07/28/11 08:26 PM Re: Section 312 Fact Act raitchjay
DCollins Offline
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Just so everyone knows, I used the FACT Act Policy on BOL and our auditor said we needed to enhance the integrity and accuracy of information provided to credit reporting agencies as outlined in Regulation V Section 222.42. So everyone that used the section under Responsibility of Furnishers of Credit Informtion may want to review their policy again.

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