U.S. Federal Reserve Board and U.S. Federal Trade Commission Issue Final Rules Implementing Dodd-Frank Credit Score Disclosure Requirements

The U.S. Federal Reserve Board and the U.S. Federal Trade Commission have issued final rules today, July 6, 2011, implementing credit score disclosure requirements in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”).

The final rules amend Regulation V, also known as the “Fair Credit Reporting Risk-Based Pricing Regulations,” to reflect new requirements in Section 615(h) of the Fair Credit Reporting Act (“FCRA”) that were added by Section 1100F of Dodd-Frank.  Creditors are required to disclose credit scores and related information in risk-based pricing notices to consumers in situations where a consumer’s credit score is used in setting the material terms of credit.  To view Regulation V, click here.

Amendments to Regulation B, entitled “Equal Credit Opportunity,” implement creditor-to-consumer adverse action notification requirements under the FCRA and the Equal Credit Opportunity Act.  The relevant model notices in Regulation B were amended to include the requirements under both statutes for creditors’ disclosure of credit scores and related information to consumers if a creditor uses a credit score in taking adverse action against a consumer.  The revised model notices reflect new content requirements in section 615(a) of the FCRA as amended by section 1100F of Dodd-Frank.  To view Regulation B, click here.

Should you have any comments or questions, please contact Colodny Fass.

To unsubscribe from this newsletter, please send an email to Brooke Ellis at bellis@cftlaw.com.