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CUNA asks for CU input on Fed equal credit plan
WASHINGTON (3/24/11)—The Credit Union National Association (CUNA) has issued a regulatory comment call on a Federal Reserve proposal that would require credit unions to disclose a member’s credit score and other information in the event of a so-called “adverse action.” Adverse actions can include instances where a credit request is rejected or an account interest rate is increased. Any key factors that adversely affected the member’s credit score, the date on which the credit score was created, and the name of the company or person that issued the credit score must also be disclosed under the Fed proposal. The proposal would add these disclosures to the model notices provided under Regulation B - Equal Credit Opportunity Act (ECOA). The new model notices would comply with the adverse action provisions of the ECOA and the Fair Credit Reporting Act (FCRA). Credit unions using the new model notices would not generally be liable for improper discrimination or use of credit information with respect to credit applications, according to CUNA. The new disclosures are required by the Dodd-Frank Act, and will become effective on July 21. CUNA in its comment call asks if the Fed should update any other model notices or forms. Credit unions may also comment on whether a portion of the proposal that requires creditors to provide both the key factors and the specific reasons for taking an adverse action should be changed. Comments should be submitted to CUNA by April 8. The Fed will receive public comments until April 14. For the comment call, use the resource link.


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