Pinnacle Investigations

Updated FCRA Disclosure

Author: Pinnacle Investigations

Updated FCRA Disclosure 

The Consumer Financial Protection Bureau (CFPB) issued an interim final rule on September 12th, 2018 with revisions to the Summary of Your Rights Under the Fair Credit Reporting Act. Employers and Background Screening companies are required to give this notice to applicants at specific times during the hiring process. 

In May 2018, Congress passed the Economic Growth, Regulatory Relief, and Consumer Protection Act. The new law requires credit reporting bureaus, under certain circumstances, to provide consumers fraud alerts and unlimited, free national security freezes and freeze releases. This is intended to make it more difficult for fraudulent accounts to be opened in a consumer’s name. 

The new law requires employers and background screening companies to provide notice regarding these new security freeze rights any time they provide a copy of the Summary of Your Rights Under the Fair Credit Reporting Act or the Remedying the Effects of Identity Theft disclosure form. The interim final rule updates the CFPB model forms to incorporate the new required notices. 

To alleviate the impact of these changes, the rule does provide that the CFPB will allow use of the prior forms (published on November 14, 2012), to constitute compliance with the FCRA provisions requiring such forms, as long as a separate page that contains the additional required information is provided in the same transmittal. 

The updated forms are effective September 21st, 2018. Pinnacle clients can download the new Summary of Rights through our user interface, or find them here: CFPB Updated FCRA Model Disclosures.

Sabrina Sawyer

Executive Vice President

Pinnacle Investigations

 


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