What is the difference between ecoa and fcra

If applicable, financial institutions can provide a combined notice of adverse action to all consumer applicants to comply with multiple-applicant requirements under the FCRA, provided a credit score is not required for the adverse action notice because a score was not relied upon in taking adverse action.

As shown in Table 3 , Regulation B includes detailed timing requirements for adverse action notices, while the FCRA does not include such requirements. Typically, financial institutions include the disclosures required under both Regulation B and the FCRA in one adverse action notice when both notices are required.

Common notice violations. Creditors may fail to identify an application as incomplete and, as such, fail to meet notice content and timing requirements. Regulation B requires the notice be in writing except for business applicants, who may receive oral notice of adverse action. Similar to the timing requirements, the contents of the disclosures under Regulation B may vary based on the type of applicant or account holder.

Common content violations. Regulation B adverse action errors involving content typically relate to the statement of specific reasons for the action taken.

The regulation requires the statement to be specific and indicate the principal reason s for taking adverse action. Specifically, the FCRA requires a person to make the following disclosures in writing or electronically as part of the adverse action notice in addition to those identified in Table 4 :. But if the credit score did not play a role in the decision to take adverse action, these disclosures are not required. Under this compliance option, the creditor provides RBP notices with credit scores to all applicants.

Dodd-Frank requires disclosure of 1 the numerical credit score used in making the credit decision; 2 the range of possible scores under the model used; 3 the key factors that adversely affected the credit score of the consumer in the model used; 4 the date on which the credit score was created; and 5 the name of the person or entity that created the score. This new information is consistent with the information that added to the risk-based pricing model notices last year.

The Board has also modified model form C-3 for clarity as it is generally used when a creditor uses a proprietary model credit system.

The new form C-3 clarifies the differences between a proprietary score and one that is obtained from a credit reporting agency. To order your report, visit annualcreditreport. Federal Trade Commission Consumer Information. Search form Search. Your Equal Credit Opportunity Rights. In this capacity, he defends institutional lenders and other creditors in consumer finance and regulatory compliance Focus litigation, including in Fair Credit Reporting Act, Real Estate Settlement Procedures Act, Truth in Lending Act, and other Litigation federal and state consumer finance litigation.

In addition, he Banking and Financial Institutions provides specific regulatory compliance advice in the non- Construction litigation context regarding a variety of federal and state consumer finance matters, an area of increased focus in the wake of the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Total views 5, On Slideshare 0. From embeds 0. Number of embeds 1, Downloads Shares 0. Comments 0. Likes 0.

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