FCRA Consumer Disclosure

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Question:

I am wondering about the consumer disclosure aspect of the Fair Credit Reporting Act. Under time of notice, it says that one may report before or no later than thirty days after reporting it to the credit bureau. If I give them notice when they take out the loan, is that prohibited under the section 623(a)(7) B.2 (Time of Notice)?

Answer:

No, providing the notice at the time of application is not prohibited. You simply must provide the notice no later than thirty days after reporting the derogatory information to the credit bureau. One warning, you must be certain that all applicants receive the notice, so if you provide the notice on the late notice, be certain that all of the borrowers receive a copy of it.

First published on BankersOnline.com 3/22/10