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#1745974 - 10/02/12 07:47 PM Change to CFPB's Address on Adverse Action Notices
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
I just read something that gave me a great deal of pain because, if it applies to me, I missed it. This refers to the "Proposed Changes to CFPB Re-publication of Consumer Regulations January 2012:"

Regulation B: The main change is changing the addresses of the federal agencies identified in adverse action notices and adding the Bureau’s. The interim rule gives creditors until January 1, 2013 to make this change.

Reg B states:
Until January 1, 2013, a creditor may comply with this paragraph (b)(1) and paragraph (a)(2) of this section by including in the notice the name and address as specified by
the appropriate agency in Appendix A to 12 CFR Part 202, as in effect on October 1, 2011.

QUESTIONS: Is this still in 'proposal' status and I have to watch out for the final rule or
Does this mean that we do not list our regulator, the FDIC, but must list the CFPB's name and address a the end of the ECOA Notice on an adverse action notice??

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#1745979 - 10/02/12 07:58 PM Re: Change to CFPB's Address on Adverse Action Notices BLPage
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
If your assets are greater than $10 billion then you need to start using the CFPB's address as of 1/1/13.

http://www.bankersonline.com/regs/12-1002/12-1002-appa.html
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1746047 - 10/02/12 09:19 PM Re: Change to CFPB's Address on Adverse Action Notices Dan Persfull
BLPage Offline
100 Club
Joined: Jan 2006
Posts: 222
Virginia
Thank you, Dan. I read that section several times, but just couldn't isolate it to mean +$10B in assets. Guess that's why I 'missed' it. Didn't apply to me....!!!

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