Identity theft is one of the fastest growing crimes in the U.S., and it is a major concern for the consumer — your customer.

The FACT Act amends the FCRA to enhance the ability of consumers to combat identity theft, to increase the accuracy of consumer reports, and to allow consumers to exercise greater control regarding the type and amount of marketing solicitations they receive.

Sheshunoff’s FACT Act Compliance Manual was designed to make it easier for your institution to adapt to the post-FACT Act FCRA. The FACT Act Compliance Manual will guide you through the regulations, identify areas that you need to focus on, and be your resource for FCRA compliance in the future.

The FACT Act Compliance Manual includes:

• Guidance on how the new Credit CARD Act of 2009 affects FACT Act compliance
• A Quick Reference Guide with a list of FACT Act provisions and how each will affect your institution
• Summaries of the key elements of the FACT Act
• Specific guidance and compliance tips for each of your departments
• Regular updates to reflect the adoption of additional regulations and other supervisory guidance

You’ll also find information about:

• Restrictions on the use of sensitive medical information in consumer reports
• Efforts to improve financial literacy among consumers

In addition, the FACT Act Compliance Manual:

• Explains how the Dodd-Frank Act affects the Fair Credit Reporting Act (with regard to credit score disclosure, red flag identity theft requirements, and records disposal) and the role the Bureau of Consumer Financial Protection will play in FCRA enforcement and regulation.
• Explains the FTC’s Amended Free Credit Reports Rule requiring certain advertisements for “free credit reports” to include prominent disclosures designed to prevent consumers from confusing these “free” offers with the federally mandated free annual file disclosures available through the single centralized source.
• Alerts you to the steps you must take now to start getting your compliance program in line with recently published risk-based pricing regulations from the Federal Reserve and the Fed­eral Trade Commission that become effective on January 1, 2011.
• Analyzes the latest, updated FCRA examination procedures that address affiliate marketing, identity theft red flags, and address discrepancies.
• Gives you the details on FFIEC Examination Guidance recently approved by the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council, pertaining to the duties of furnishers of consumer information to a consumer reporting agency.
• Details final amendments from the OCC, FRB, FDIC, OTS, NCUA, FTC, CFTC, and SEC to their rules that implement the privacy provisions of Subtitle A of Title V of the Gramm-Leach-Bliley Act, and require financial institutions to provide initial and annual privacy notices to their custom­ers. The agencies adopted a model privacy form that financial institutions may rely on as a safe harbor to provide disclosures under the privacy rules.

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