The Consumer Financial Protection Bureau (CFPB) issued an interim final rule on two model disclosure forms – the Summary of Consumer Identity Theft Rights and the Summary of Consumer Rights as required by the Fair Credit Reporting Act (FCRA) and Regulation V. The changes were mandated as part of the recently passed Economic Growth, Regulatory Relief, and Consumer Protection Act (S. 2155).

S. 2155:

  • Requires nationwide consumer reporting agencies to provide “national security freezes” free of charge to consumers;
  • Mandates that whenever the FCRA requires a consumer to receive either the Summary of Consumer Rights or the Summary of Consumer Identity Theft Rights, a notice regarding the new security freeze right also must be included; and
  • Extends to one year (up from 90 days) the minimum time that nationwide consumer reporting agencies must include an initial fraud alert in a consumer’s file.

Congress set an effective date of September 21, 2018 for these changes.

The interim final rule updates the Bureau’s model forms, incorporating the new required notice and the change to the minimum duration of initial fraud alerts. The Bureau invites comment on these changes and any other aspects of the Bureau’s model forms.  To read the interim final rule and learn how you can weigh in with the Bureau about these updates, click here.