I have procedures for all of FACT Act. For those rules not yet finalized, they are pretty basic, awaiting the final rules. Rules in effect: fraud alerts; information to be available to identity theft victims; blocking reporting information claimed to be result of identity theft; credit scores isclosures to mortgage applicants; notification to consumers about report of negative information to consumer reporting agencies; duty to furnish accurate information, disposal of records containing consumer report information & prescreening opt-out notice (from ABA Bank Compliance Set/Oct 2005 magazine)
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Treading water in a hurricane