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#1757933 - 11/14/12 06:02 PM New model forms under Reg V
Sewanee, CRCM Offline
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TN
OK-I'm having a thick brain day. Can anyone tell me under what circumstances these revised forms are to be used?

Bureau publishes Reg V corrections
The CFPB has published in today’s Federal Register corrections to Appendices I, K, M and N to its interim final Regulation V (Fair Credit Reporting Act), issued on 12/21/2011. Use of the December 2011 model forms in those appendices will be accepted until further notice from the Bureau, which is expected at some time in 2013.
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#1758043 - 11/14/12 08:43 PM Re: New model forms under Reg V Sewanee, CRCM
ccman Offline
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Apparently to be used by the CRA's, but with the Bureau's address and some typo corrections.

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#1801240 - 04/03/13 10:26 PM Re: New model forms under Reg V ccman
travelgirl Offline
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I had a reminder on my task list to circle back and see if there was anything out on this. A previous co-worker had it on their to-do list and has now been put in my lap.

I'm confused really on what I'm waiting for. Is this for banks or just consumer reporting agencies?

I've already changed my adverse action/FCRA forms to state the CFBP contact info. Does this have to do with that or is it something entirely different?

If it's different AND applies to banks, can someone provide a link to information so I can read more about it.

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#1801243 - 04/03/13 10:40 PM Re: New model forms under Reg V Sewanee, CRCM
rlcarey Offline
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I've already changed my adverse action/FCRA forms to state the CFBP contact info.

I assume they are your primary regulator - correct?
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#1801258 - 04/03/13 11:20 PM Re: New model forms under Reg V rlcarey
travelgirl Offline
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No, it's the FDIC. I'm confusing myself. I updated my Credit Score Disclosures with CFPB info not NAT.

Is that all I needed to do or is whatever came out in December 2011 (to be finalized by the CFPB in 2013) something add'l that i need to worry about?

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#1801284 - 04/04/13 12:18 PM Re: New model forms under Reg V Sewanee, CRCM
rlcarey Offline
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What exactly do you mean by "Credit Score Disclosures"?
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#1802660 - 04/09/13 02:06 PM Re: New model forms under Reg V rlcarey
travelgirl Offline
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It's the disclosure we give on consumer loans when we "use" a credit score in our decision in lieu of following the Risk Based Pricing rules. The "here is your score, here are the ranges, here are the key factors that went into your score."

At the bottom of the disclosure there is a section that reads:

How can you get more information?
For more information about credit reports and your rights under federal law, visit the Consumer Financial
Protection Bureau's website at www.consumerfinance.gov/learnmore .

I had to make sure the CFPB was listed here now.

I guess my question is - is anyone aware of any other "new" or "updated" model forms (from the last 6 mos or pending) that are required under Reg V besides the form I listed above?

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#1802691 - 04/09/13 02:47 PM Re: New model forms under Reg V travelgirl
Ted Dreyer Offline
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All of the Risk-based pricing model forms, including the one you mentioned, had the same change made to add the CFPB information. The only other changes are the ones mentioned earlier in this thread that affect forms given by the consumer reporting agencies rather than financial institutions.

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#1802897 - 04/09/13 07:00 PM Re: New model forms under Reg V Ted Dreyer
travelgirl Offline
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Minnesota
Perfect. Thanks to those that responded.

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#1825509 - 06/20/13 03:00 PM Re: New model forms under Reg V Ted Dreyer
complianceassist Offline
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Where can I find the info changing the website from the Fed/FTC to the CFPB?

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#1825549 - 06/20/13 03:31 PM Re: New model forms under Reg V complianceassist
Ted Dreyer Offline
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It's in the Model forms from when they were republished by the CFPB in December of 2011: Link

They changed the model forms at that time to include the CFPB website, but gave some time to change the forms by including in instruction 3(a)(ix) that an acceptable change was:

"Until January 1, 2013, substituting “For more information about credit reports and your rights under Federal law, visit the Federal Reserve Board's Web site at www.federalreserve.gov, or the Federal Trade Commission's Web site at www.ftc.gov. ” for “For more information about credit reports and your rights under Federal law, visit the Consumer Financial Protection Bureau's Web site at www.consumerfinance.gov/learnmore.

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