Has anyone given thought to if the new disclosure, required by 7/16, telling the customer you may give negative information to a credit reporting agency, would apply to deposit accounts? Technically, not "credit" by definition, but what if you have one of those OD programs?

There is another thread on this but yes, it will as you look at Reg. B's definition, not Z.

Quote:

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required by 7/16

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If you reread the regulation, the model notice language is final as of 7/16 but the requirement to give the notice contained in section 217 of the FACT Act has an effective date of December 1.

I looked for it before I posted, but apparently missed it. Any help you can give me to point me in the right direction will be appreciated.

The document with the model notices is at:

http://www.federalreserve.gov/boarddocs/press/bcreg/2004/200406082/attachment.pdf

On page 2 it says:

"Section 217 of the FACT Act requires that if any financial institution (1) extends credit and regularly and in the ordinary course of business furnishes information to a nationwide consumer reporting agency, and (2) furnishes negative information to such an agency regarding credit extended to a customer, the institution must provide a clear and conspicuous notice about furnishing negative information, in writing, to the customer. Section 217 defines the term “negative information” to mean information concerning a customer’s delinquencies, late payments, insolvency, or any form of default. The term “credit” is defined under the FACT Act to have the same meaning as in section 702 of the Equal Credit Opportunity Act, which defines “credit” to mean “the right granted by a creditor to a debtor to defer payment of debt or to incur debt and defer its payment or to purchase property or services and defer payment therefor.” 15 U.S.C. 1691a. The provisions in Section 217 will become effective December 1, 2004. 69 FR 6526, (February 11, 2004)."

Thanks! I have the document, but I was looking for the thread that discussed the impact on deposit accounts that Andy referred to. Appreciate the help!!!!!