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FCRA – the 800 Pound Compliance Gorilla

12.10.25 | 2:30 PM EST
Instructor: Rebekah Leonard

Course Duration: 2 HR

What You'll Learn

It’s no exaggeration:  Regulations implementing the FCRA represent some of the most underrated rules in banking. Their reach extends far and wide within financial institutions, covering everything from deposit accounts to loans; Human Resources to Marketing. 

Consider it the 800 pound gorilla you didn’t even know you had in the room. Left unchecked, it could make a huge mess of things! Is your Compliance Management System adequately addressing all the numerous facets of FCRA?  Gaps occur frequently, simply because so many bank players need to be involved.  If you only have an FCRA lending policy, you are undoubtedly leaving off about half the coverage of FCRA. 

AGENDA

Lending Issues:

  • Permissible purpose
  • When medical information may be considered (but should it?)
  • Accurate adverse action notice disclosures (far more to them than just Reg B)
  • Risk Based Pricing Notices
  • Credit score disclosures (several varieties)
  • Fraud alerts
  • Accurate credit reporting (i.e. lenders can’t waive bad reporting for good customers)
  • Furnishing of negative information
  • Dispute and error resolution
  • Prescreening solicitations (which may impact your customers even if your institution isn’t doing them… Hello “trigger leads”!)

Deposit / Operational Issues:

  • Permissible purpose (yep, again)
  • Affiliate information sharing and what it means for marketing
  • Deposit account adverse action notice disclosures
  • Accurate credit reporting (E-OSCAR)
  • Re-pollution of data
  • Identity Theft Prevention Program (i.e. Red Flags program)
  • Disposal of consumer information
  • Prescreening solicitations (yes, here too!)

Employment Issues:

  • Permissible purpose (I sense a theme…)
  • Employment credit reports (Unique – don’t substitute credit reports pulled on the loan side!)
  • Required pre-pull disclosures
  • Employment adverse action notice disclosures

Accreditations

CPE/NASBA - Group Internet Based

Noggin Guru, Inc. dba Lorman Education Services and BankersHub is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539.

Please note: You must attend at least 50 minutes to obtain credit. Final CPE approval belongs with each state's regulatory board. Credit is based on a 50-minute credit hour.

For more detailed information about the course, including the outline, content, and objectives, please refer to the 'Description' tab on this webpage.

Field Of Study: Business Law
Prerequisite: Basic knowledge of the banking industry, business, or law
Level of Knowledge: Intermediate
Advanced Preparation: None
Delivery Method: Group Internet Based

Requesting CE:
Upon completion of this course, please email creditrequest@nogginguru.com to obtain a CE certificate.

About the Author:

Rebekah Leonard
Rebekah Leonard
Rebekah is the owner of Elucidate LLC, a compliance training and consulting company. Elucidate means to "make clear, explain, throw light upon", and describes Rebekah's desire to illuminate the complexities of compliance with passion and fun. She's created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences. She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource. Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana. She began her career in 1995 at a private lending company, but soon settled into banking, where she's covered nearly all of it - customer service and teller work, loan processing and review, and security and business continuity. She now oversees CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor's degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.

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