Skip to content
BOL Conferences
Thread Options
#244143 - 09/14/04 02:50 PM FACTA Notice Requirements & FDIC
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
It appears to me that the recently implemented Reg. V notice requirements do not cover state non-member banks (FDIC supervised). The FDIC has come out with some proposed rules that implement parts of the FACTA but I cannot seem to find either a proposal or an implemented rule for the notice requirement (section 217). I've searched the Boards and checked the FDIC site. Has the FDIC addressed this issue????
_________________________
If you keep living straight from the heart, you will know when to stop and to start.

Return to Top
#244144 - 09/14/04 04:29 PM Re: FACTA Notice Requirements & FDIC
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
The statutory section of the FACT Act on these notices, Section 217, provides that "any financial institution" that extends credit and furnishes information to a nationwide CRA must give the notice. The Federal Reserve just issued the model notices which are not required, but provide a safe harbor. Section 222.1 (b)(2)(ii) of the Federal Reserve issuance provides that other financial institutions (such as FDIC-regulated banks) MAY use the model notices to comply with the notice requirement contained in the FCRA.

Return to Top
#244145 - 09/14/04 06:37 PM Re: FACTA Notice Requirements & FDIC
Last Mango Offline
Gold Star
Joined: Mar 2001
Posts: 293
Too Far From the Beach
Guess I should stop relying on summaries by other entities.

Thanks Ted!
_________________________
If you keep living straight from the heart, you will know when to stop and to start.

Return to Top