Recent Final Rule Analyses

CUNA
January 9, 2008 | COMMENTS

Federal Trade Commission Notice Regarding Charges Permitted Under the FCRA

The Fair Credit Reporting Act (FCRA), as amended in 1996, states that where a consumer reporting agency is permitted to charge a reasonable fee for making a disclosure to a consumer, the fee should not exceed $8.00. This fee became effective in 1997 and is required to be adjusted based on the Consumer Price Index (CPI), rounded to the nearest fifty cents.

As a result of the latest CPI adjustment, the fee will be increased from $10.00 to $10.50, effective as of January 1, 2008.

This fee will not apply to consumers' requests for a free annual credit report under the provisions of the Fair and Accurate Credit Transactions Act of 2003 (FACTA). It will apply to additional requests, unless the consumer is also entitled to receive them without charge.

If you have questions about the notice, please contact Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com or by telephone at (202) 508-6736 or contact Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com or by telephone at (202) 508-6732. If you would like a copy of the announcement, contact Jeff by e-mail or by telephone. You may also click here for a copy.

Fed Increases the Home Mortgage Disclosure Act (HMDA) Asset-Size Exemption Threshold

The Federal Reserve Board (Fed) has issued its annual notice of the asset size of financial institutions that are required to comply with the HMDA data collection requirements.

The asset size will increase from $36 million to $37 million. Financial institutions with assets of $37 million or less as of December 31, 2007 will be exempt from the data collection requirements 2008.

These annual notices and adjustments are required under the Economic Growth and Regulatory Paperwork Reduction Act of 1996, and any adjustments are based on the Consumer Price Index for Urban Wage Earners and Clerical Workers.

If you have questions about the notice, please contact Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com or by telephone at (202) 508-6736 or contact Senior Assistant General Counsel Jeff Bloch at jbloch@cuna.com or by telephone at (202) 508-6732. If you would like a copy of the announcement, contact Jeff by e-mail or by telephone. You may also obtain a copy on the Internet by clicking here.