FCRA – the 800 Pound Compliance Gorilla

On Demand Course

Instructor: Rebekah Leonard

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

*This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

About the Author:

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.

On-Demand Course