Well, there's more to the FACT Act than just reporting to the bureaus. For instance, if you use the credit score from the credit bureau in your risk-based pricing program, you have a new disclosure. If you have an affiliate, and you share information which the affiliate will use in a marketing solicitation, you will need to provide opt-out first. If a customer notifies you that a debt on your books is the result of their identity being stolen, you'll be limited in your ability to transfer, sell, or place that debt for collection. You'll need to establish some training for those who read credit reports, so that they can take steps to verify the identities of those who've placed alerts in their reports, prior to extending credit. You may need new procedures relating to address changes & issuing new or replacement credit or debit cards.
This act touches a lot of different areas of the bank - moreso than just reporting to the bureaus. We're spending some time with it, but are really waiting for the regulations to come out this fall.
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."