As I understand it, banks that make consumer 1-4 unit residential mortgage loans are now required to give the "Notice to Home Loan Applicants" if a credit score was provided by a CRA. The Act states that the notice shall include the name, address, and telephone number of the CRA providing the credit score. It appears that the score as well as the factors affecting the score also have to be disclosed? Just wondering if this is now required and if my understanding is accurate, and if so, how some of you are complying as far as what CRA information your giving the applicant with the notice, and when. It gets confusing trying to compare the recently published Federal Reserve's "effective dates" to HR 2622 (FACTA). Does anyone have a summary of what is effective when? Thanks!!

Thanks for responding MackensieS! I did see your post earlier and DO SYMPATHIZE with you!! In HR 2622 there is language for this particular notice but I'm having trouble determining if it falls under the 12/31/03 effective date for various requirements as noted in the Federal Register vol. 69 dated 2/11/04. I'll wait for the final regs also unless someone can answer the initial question(s). I agree with your other post, that all of this could be matched up better.

If I remember correctly, the biggest effect of 12/31/03 was the pre-emption rule. (State law can lo longer supercede Federal law) Just remember that for things such as having to prepare/distribute new documents or disclosures they HAVE to give us more time to get with our vendors to have these docs created/modified, get the employees trained on when to provide them, etc., so generally you won't see those types of regulatory changes come into affect as quickly.

What you are referring to is Section 212 of the FACT Act and the new Section §609 of the FCRA. That should have an effective date of 12-01-04, based on the implementation dates of the new rules.