On September 12, 2018, the Bureau issued an Interim Final Rule (the “Rule”) updating two Fair Credit Reporting Act (“FCRA”) model disclosures. These amendments were made in response to the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Act”) which became law in May 2018. The Act requires consumer reporting agencies (“Credit Bureaus”) to provide “national security freezes” free of charge. To implement this change, whenever the Credit Bureaus are required to provide consumers with either the Summary of Consumer Rights or the Summary of Consumer Identity Theft Rights, the Act mandates that the Credit Bureaus also notify consumers about security freezes.
The Act also extends the period of time that the Credit Bureaus must include an initial fraud alert on the consumers file from 90 days to one year. The updated model forms incorporate the new required notice and the duration change for the initial fraud alerts. This change is effective September 21, 2018, but the Credit Bureaus may continue to use the forms published on November 14, 2012 so long as a separate page containing the additional disclosures is also provided.
Links:
The Rule is available here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/summaries-rights-under-fair-credit-reporting-act-regulation-v/
The Press Release is available here: https://www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-updated-fcra-model-disclosures/