Do you have a policy of reusing credit reports? You may want to re-evaluate that practice, given the growing regulatory and potential legal concerns in this area. For example, reusing a previous credit report could potentially impact your Ability to Repay calculation if you don’t have current credit information. Also, credit scores could be inaccurate and fraud alerts could be missed. Add to that, the Military Lending Act, where the safe harbor has specific timing requirements. And one other consideration – your contract with the consumer reporting agency may prohibit the reuse of credit reports.
If you’re looking to stay on top of regulatory hot spots or just a refresher on the provisions of the FCRA and FACT Act, join us for our FCRA / FACT Act webinar on September 19, 2017.