FCRA Policy Template Update Details

What's New

Topic 5 - Structure of Accountability. Includes the following subtopics:

Board of Directors and Senior Management

Compliance Officer

Compliance Committee

Topic 18 - Duties of Card Issuers Regarding Changes of Address. Includes the following subtopics:

General

Alternative Timing of Address Validation

Form of Notice

Topic 19 - Affiliate Marketing Policy. Includes the following subtopics:

Policy Statement

Enforcement

Exceptions to Policy

Regulatory Background

Affiliate Marketing and Opt-Out Exceptions

Scope and Duration of Opt-Out Requirements

Opt-Out Notices

Opportunity of Opt-Out

Opt-Out Methods

Delivery of Opt-Out Notices

Renewal of Opt-Out

Topic 20 - Audit Policy. This topic provides guidance with respect to a financial institution's requirement to conduct periodic independent audit reviews of its FCRA/FACTA and identity theft compliance activities.

Fair Credit Reporting Act Sample Opt-Out Notices Form Template (5 pages). This new form template product is included with the purchase price of this policy template, and includes the following notices:

Initial Opt-Out Notice - Single Affiliate

Initial Opt-Out Notice - Joint Affiliates

Renewal Notice - Single Affiliate

Renewal Notice - Joint Affiliates

Voluntary No Marketing Notice

What's Revised

Topic 2 - Policy Statement. The "General" subtopic was revised to add a statement regarding a financial institution's Identity Theft Program.

Topic 4 - Definitions. 14 new definitions were added.

Topic 10 - Identity Theft Program Policy. Formerly entitled "Identity Theft and Social Engineering Procedures" (Topic 9), the following subtopics were added:

Policy Statement

Enforcement

Exceptions to Policy

Identity Theft Program Overview

Risk Assessment Process

Red Flag Categories and Detection

Identity Theft Prevention and Mitigation Techniques

Topic 15 - Sharing Information with Affiliates. A new subtopic entitled "Affiliate Marketing" was added to reference this new topic within the policy.

Topic 16 - Disputed Information. Formerly Topic 15, a new subtopic entitled "Notice of Address Discrepancy Procedures" was added.

Topic 22 - Retention of Documentation. Formerly Topic 18, minor changes were made to reflect protection and archive techniques employed by a financial institution.

Identity Theft Affidavit Packet Form Template (9 pages). Additional governmental agency or service contacts were added to page three. New tracking column areas were added to the "Document Checklist" section to include:

Credit Bureaus

Creditors

Account Statement Reviews

Internet Banking Access

Law Enforcement Authorities

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