We are not scheduled until next year for our exam, but I am wondering if anyone has any feedback as to what the examiners are looking at regarding FCRA/FACT during examinations.

Thanks.

If you are an OCC bank you might want to pay attention to the new examination procedures.

The other regulators are probably not far behind.

DQ

We recently had an exam and the OCC looked over our implementation plan, policy and procedures. They had minor suggestions for our procedures for clarification purposes - not a big deal. As far as I know they didn't do any transactional testing this time around.

Oh - I should add the exam procedures weren't out yet when they were here, but I made sure to read them and will ensure we are covering our bases.

The problem is that many of the most significant changes from the FACT Act are not in effect yet because regulations have not been issued. If these come out and are effective before your exam, the landscape could change considerably from the situation now.

Thanks all, I wasn't really worried about it, but was sort of wondering if they even were looking at it.

(Our training is documented... )

Anyone have an audit experience with the FDIC for FACT Act? Thanks!

Just completed FDIC Compliance Exam and they asked for forms, they quizzed us about how we initially notified consumers of negative information and on an ongoing basis, identity theft, fraud alerts, repolluting the credit bureau, use of credit scores on home secured loans, and I'm sure during their file review they were looking for these forms. They did ask about medical information even though it's not yet effective.

We have a Jan. 27th webinar on FACT Act auditing.