NEGATIVE INFORMATION DISCLOSURE

Will the language contained on the URLA in Section IX. Acknowledgement and Agreement (8) cover the requirement for Negative Information Disclosure?

1022 APPENDIX B
Model Notice B–1
We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.

Model Notice B–2
We have told a credit bureau about a late payment, missed payment or other default on your account. This information may be reflected in your credit report.

I think at application you are really pushing the envelope.

Section 623(a)(7) (B) Time of Notice

(i) In general. The notice required under subparagraph (A) shall be provided to the customer prior to, or no later than 30 days after, furnishing the negative information to a consumer reporting agency described in section 603(p).

(ii) Coordination with new account disclosures. If the notice is provided to the customer prior to furnishing the negative information to a consumer reporting agency, the notice may not be included in the initial disclosures provided under section 127(a) of the Truth in Lending Act.

IMHO the comment that is hidden in section IX of the URLA is a far cry from "clear and conspicuous".