FACT Act Final Rule Issued
By Deb Jost
Amidst all the commotion of Reg Z and RESPA changes, final rules implementing the accuracy and integrity and direct dispute provisions in section 312 of the Fair and Accurate Credit Transactions Act (FACT Act) have also been issued. Fortunately, you have until July 1, 2010 to comply with these rules!
Under the final rule, furnishers of consumer information, to a consumer reporting agency, must consider the guidelines set forth in Appendix E in establishing "reasonable" policies and procedures for implementing the guidelines. Furnishers must review the policies and procedures and update them as necessary.
In addition, the guidelines identify circumstances under which a furnisher must reinvestigate disputes about the accuracy of information contained in a consumer report. Similar to Reg E, the guidelines define what constitutes a "direct dispute", outline exceptions (got to have them) to the requirements, and establish what is considered "frivolous" or "irrelevant" disputes.
Watch for the full details in an upcoming newsletter....after you've had time to absorb the Reg Z and RESPA changes!