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.
Published
2017/09/12
Deb Irving
Deb joined Banker’s Compliance Consulting with twenty years of experience in the banking industry. Her past positions include teller, credit review analyst, assistant financial officer, BSA Officer, Compliance Officer, and Director of Compliance. She has worked for both a small community bank and a large billion-dollar bank.
Deb has Associate Degrees in Business Management and Accounting. She is a graduate of the American Bankers Association National Graduate School of Compliance Management, an honors graduate of Schools of Banking Compliance School, and a graduate of Schools of Banking Advanced School of Banking. Deb’s considerable knowledge and experience make her a valuable member of the Banker’s Compliance Consulting Team. Deb is a Certified Regulatory Compliance Manager (CRCM) and a Certified Anti Money-Laundering Specialist (CAMS).
Deb loves to spend her free time cycling, running, kayaking and weight lifting with her husband. Between them, they have three adult children and six grandchildren. Other interests include anything outdoors and anything she hasn’t done or seen yet!