The recently enacted S. 2155 contains several provisions related to the Fair Credit Reporting Act (FCRA) that will impact how credit unions report certain information.   This new law will enhance consumer protections under the FCRA in several ways.

Section 301:

  • Requires credit bureaus to provide fraud alerts on consumer credit reports for at least one year (up from 90 days) when notified by an individual who believes he or she has been or may become a victim of fraud or identity theft; and
  • Provides consumers the right to place (and remove) a security freeze on their credit reports free of charge (in the case of a minor, the parent or authorized representative may request the credit freeze).

Section 302:

  • Mandates that certain medical debts incurred by a veteran be excluded from the veteran’s credit report until one year has passed from when the medical service was provided (credit bureaus had already implemented a six-month delay);
  • Requires the removal of veterans’ delinquent medical debts from credit reports once they are fully paid or settled;
  • Establishes a dispute process and verification procedures for veterans’ medical debts contained in consumer credit reports;
  • Requires the Veterans Administration to establish a database within one year to allow consumer reporting agencies to verify whether a debt furnished to a consumer reporting agency is a veteran’s medical debt subject to these new protections; and
  • Requires free credit monitoring to active duty military members that would alert them to material changes in their credit scores.

Section 602:

  • Allows consumers to request information related to a default on a qualified private student loan be removed from a credit report if the borrower satisfies the requirements of the lender’s loan rehabilitation program (as approved by the lender’s regulator).

More details will follow in the coming weeks as industry and regulators work through the new law.  CUNA’s Compliance Community can also serve as a resource in the interim.  This space contains discussion boards and a number of other resources for credit union compliance professionals.