Dear XXXXXXX XXXXXXX,
Equifax is offering a solution to assist our customers with their compliance with the adverse action and risk-based pricing notification requirements that are a result of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act (CFPA).
Please review this communication to better understand Equifax's solution in light of the timing and scope of the legislation, the potential impact on your organization and the appropriate Equifax contacts to address your specific needs.
Legislative Action
The Dodd-Frank Wall Street Reform and Consumer Financial Protection Act, approved in July 2010, will give consumers free access to their credit scores if they are denied a loan, receive unfavorable terms on a loan, or if they are otherwise adversely affected because of poor credit (i.e., turned down for a job or an apartment).
Impending Change
The CFPA revises Section 615 of the Fair Credit Reporting Act (FCRA) to state: "If any person takes any
adverse action with respect to any consumer that is based on whole or in part on any information contained in
a consumer report," the person shall:
• Provide an adverse action notice.
• Provide a score disclosure (including the credit score, the range of the score, four or up to five reason codes if inquiries adversely affected the credit score, the date the score was calculated and the name of the Credit Reporting Agency [CRA]).
• Provide the name, address and phone number of the CRA that furnished the credit report.
• Provide a statement that the consumer reporting agency did not make the decision to take the adverse action and is unable to provide the consumer the specific reasons why the adverse action was taken.
• Provide notice of the consumer's right to obtain a free copy of a consumer report from the CRA within 60 days and notice of the consumer's right to dispute with a CRA the accuracy or completeness of any
information in a consumer report furnished by the CRA."
* Bold denotes new FCRA requirement
Timeline
Equifax's solution will be ready by July 21, 2011, the "designated transfer date" on which the Bureau of Consumer Financial Protection will assume powers of various agencies, including the Federal Trade Commission, specified by the CFPA.
How Equifax Can Help
Equifax is finalizing our standard solution, which will enable the delivery of what is referred to as the "Fifth factor," the score range and the date the score was calculated for its online and offline generic scoring models.
Specifications for the delivery of the online System-to-System solution will be available within the next 10 days. The change in the rules may mean that your custom scoring models may be impacted. Please consult with your internal Compliance and Legal teams, referring them to the Dodd-Frank legislation section 1100F.
Your Equifax Resources
Contact your Equifax Sales Representative as soon as possible should you require an assessment and/or update to your custom scoring model(s).
Please contact your Equifax CMS Project Manager should you require custom fulfillment file delivery of the score disclosure requirements.
Thank you for your business and for your partnership in addressing and managing the impact of important public policies on our industries.
Sincerely,
Equifax Customer Service
Equifax is offering a solution to assist our customers with their compliance with the adverse action and risk-based pricing notification requirements that are a result of the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act (CFPA).
Please review this communication to better understand Equifax's solution in light of the timing and scope of the legislation, the potential impact on your organization and the appropriate Equifax contacts to address your specific needs.
Legislative Action
The Dodd-Frank Wall Street Reform and Consumer Financial Protection Act, approved in July 2010, will give consumers free access to their credit scores if they are denied a loan, receive unfavorable terms on a loan, or if they are otherwise adversely affected because of poor credit (i.e., turned down for a job or an apartment).
Impending Change
The CFPA revises Section 615 of the Fair Credit Reporting Act (FCRA) to state: "If any person takes any
adverse action with respect to any consumer that is based on whole or in part on any information contained in
a consumer report," the person shall:
• Provide an adverse action notice.
• Provide a score disclosure (including the credit score, the range of the score, four or up to five reason codes if inquiries adversely affected the credit score, the date the score was calculated and the name of the Credit Reporting Agency [CRA]).
• Provide the name, address and phone number of the CRA that furnished the credit report.
• Provide a statement that the consumer reporting agency did not make the decision to take the adverse action and is unable to provide the consumer the specific reasons why the adverse action was taken.
• Provide notice of the consumer's right to obtain a free copy of a consumer report from the CRA within 60 days and notice of the consumer's right to dispute with a CRA the accuracy or completeness of any
information in a consumer report furnished by the CRA."
* Bold denotes new FCRA requirement
Timeline
Equifax's solution will be ready by July 21, 2011, the "designated transfer date" on which the Bureau of Consumer Financial Protection will assume powers of various agencies, including the Federal Trade Commission, specified by the CFPA.
How Equifax Can Help
Equifax is finalizing our standard solution, which will enable the delivery of what is referred to as the "Fifth factor," the score range and the date the score was calculated for its online and offline generic scoring models.
Specifications for the delivery of the online System-to-System solution will be available within the next 10 days. The change in the rules may mean that your custom scoring models may be impacted. Please consult with your internal Compliance and Legal teams, referring them to the Dodd-Frank legislation section 1100F.
Your Equifax Resources
Contact your Equifax Sales Representative as soon as possible should you require an assessment and/or update to your custom scoring model(s).
Please contact your Equifax CMS Project Manager should you require custom fulfillment file delivery of the score disclosure requirements.
Thank you for your business and for your partnership in addressing and managing the impact of important public policies on our industries.
Sincerely,
Equifax Customer Service
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