A review of the Bank’s compliance with all Fair Credit Reporting Act requirements should be periodically completed. Our comprehensive review scope will include testing for compliance with applicable FCRA examination procedures not covered in our Loan Origination and Deposit Compliance Reviews and will serve as an annual assessment of the Bank’s Identity Theft program. The following FCRA requirements will be reviewed via the Fair Credit Reporting Act / ID Theft review:
- Permissible Purposes of Consumer Reports
- Investigative Consumer Reports
- Consumer Report and Information Sharing
- Protection of Medical Information
- Affiliate Marketing Opt-Out
- Use of Consumer Reports for Employment Purposes
- Prescreened Consumer Reports and Opt-Out Notice
- Truncation of Credit and Debit Card Numbers
- Disclosure of Credit Scores by Certain Mortgage Lenders
- Adverse Action Disclosures
- Debt Collector Communications concerning Identity Theft
- Duties of Users Regarding Risk-based Pricing
- Duties of Users of Credit Reports Regarding Address Discrepancies
- Duties of Furnishers of Information
- Prevention of Re-Pollution of Consumer Reports
- Negative Information Notice
- Fraud and Active Duty Alerts
- Information Available to Victims
- Duties of Card Issuers Regarding Changes of Address
- Identity Theft Red Flags