THE FAIR AND ACCURATE CREDIT TRANSACTION ACT (FACT ACT)
COMPLIANCE PROGRAM
TABLE
OF
CONTENTS
Introduction
O UR
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U S E RS O F C O N S U M E R R E P O R TS
Permissible Purposes
Permissible Purposes – as an Employer
Fraud and Active Duty Alerts (effective date 12/01/04)
Adverse Action Notices (effective date 12/31/03) (update – 2013)
“Prescreening” (effective date 08/01/05)
Address Discrepancies (effective date 11/01/08)
Disposal of Records (effective date FCU’s 12/29/04 SCU’s 06/01/05)
Notice to Home Loan Applicants/Disclosure of Credit Scores (effective date 12/01/04)
Protection of Medical Information (effective date 04/01/06)
Risk Based Pricing Notice (effective date 01/01/11) (update – 2011)
RE S PO N S I BI L I TI E S AS F UR N I S HE RS O F I N F O R M A TI O N
Accuracy and Integrity of Information (effective date 07/01/10)
Prevention of Re-Pollution (effective date 12/01/04)
Negative Information Notice (effective date 12/01/04)
ID Theft “Red Flags” Prevention Program (effective date FCU’s 11/1/08 SCU’s 12/31/10)
RE S PO N S I BI L I TI E S AS
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M I S CE L L AN E O US RE Q U I R E M E N TS
Free Annual Credit Reports (member education)
Sharing Information and Marketing with Affiliates (effective date 10/01/08)
Truncation of Credit/Debit Card Users (effective date 12/01/06)
Program Approval
A T T A C HM E N TS
Adverse Action Notice (rev. 2013)
Member Dispute Notice
Third-Party Amendment to Agreement
Risk-based Pricing Notice (rev. 2013 – for general notice requirements if no score is used)
Risk-based Pricing Notice (rev. 2013 – for general notice requirements if score is used)
No Credit Score Notice (rev. 2013)
Account Review Risk Based Pricing Notice (rev. 2013 – if no score is used)
Account Review Risk Based Pricing Notice with Credit Score Information (rev. 2013)
Credit Score Disclosure for Loans Not Secured by Residential Real Property (rev. 2013)
Credit Score Disclosure for Loans Secured by Residential Real Property (rev. 2013)
Notice to the Home Loan Applicant
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FACT ACT COMPLIANCE PROGRAM
INTRODUCTION
The Fair Credit Reporting Act (FCRA) deals with the rights of consumers in relation to their credit reports and the
obligations of credit reporting agencies and the businesses that provide information to them. The FCRA has been
revised numerous times, most recently by passage of the Fair and Accurate Credit Transactions Act of 2003 (FACT
Act).
The FACT Act created new responsibilities for financial institutions, including developing an Identity Theft
Prevention Program, providing more information to consumers about credit reports and credit scoring, limiting
sharing of information to affiliates, providing certain disclosures and reconciling potentially fraudulent address
information. It also created new rights for consumers, including the right to free annual consumer reports, new
identity theft protection and new medical privacy rights.
PERMISSIBLE PURPOSES
OF CONSUMER REPORTS
The credit union may obtain a consumer report for the following purposes:
 For the extension of credit as a result of an application from a member or consumer
 For the review or collection of a member’s account
 To review a member’s account to determine whether the member continues to meet the terms of the
account.
 When there is a legitimate business need, in connection with a business transaction that is initiated by the
member/consumer
 For employment purposes, including hiring and promotion decisions, the procedure is set forth below.
USE OF CONSUMER REPORTS FOR EMPLOYMENT PURPOSES
In the event the credit union obtains a consumer report for employment purposes, we will:
 Make a clear and conspicuous written disclosure to the applicant before the report is obtained, in a document
that consists solely of that disclosure.
 Obtain from the applicant prior written authorization. The credit union may obtain authorization to access
reports during the term of employment at the time of employment.
 Certify to the credit reporting agency (CRA) that the above steps have been followed, that the information
being obtained will not be used in violation of any federal or state equal opportunity law or regulation, and
that, if any adverse action is to be taken based on the consumer report, a copy of the report and a summary of
the applicant/employee‘s rights will be provided.
 Provide a copy of the report to the applicant/employee as well as the applicant/employee’s rights before
taking an adverse action.
 Comply with, and refer to, Section 603(x) of the FCRA for procedures concerning investigations of suspected
misconduct by an employee.
FRAUD
AND ACTIVE DUTY ALERTS
If the credit union receives a credit report that contains an initial, extended or active duty alert, we will adhere to
the following:
 Prior to the issuance of any loan (other than advances on an existing open-end plan), new or additional credit
cards, or increase of a credit limit, the credit union will re-confirm the identity of the member using acceptable
CIP procedures so as to form a reasonable belief of the true identity of the person making the request.
 In the case of initial active duty alerts, key staff will contact the member using the specified telephone number
in the alert or any acceptable CIP measure to verify the identity of the person making the request and confirm
that the request is not the result of ID theft, BEFORE credit is extended.
 Upon receipt of an extended alert or if an alert contains instructions to contact the consumer before taking
any action on the request, key staff must contact the member, either by using the specified telephone number
in the alert or by a method that involves personal contact.
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ADVERSE ACTION DISCLOSURES
Effective July 2011, the Federal Reserve Board (Board) and the Federal Trade Commission (FTC) issued final rules
to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer
Protection Act. If a credit score is used in setting material terms of credit or in taking adverse action, the statute
requires creditors to disclose credit scores and related information to consumers in notices under the Fair Credit
Reporting Act (FCRA).
The credit union will notify an applicant/member of action taken on a request for credit, whether favorable,
adverse, or incomplete within 30 days after receiving the completed application. Notice of approval may be
provided orally, and all notifications of adverse action, including incomplete application, will be in writing. When
adverse action is taken on an existing account notification will be made within thirty days. If the adverse action is
based on consumer report information that was obtained from an affiliate, and the member requests the nature of
information relied upon within 60 days of receiving the notice, the credit union will respond no later than 30 days
after receiving the request.
To ensure compliance with the Equal Credit Opportunity Act, the credit union will utilize a combined FCRA/ECOA
adverse action form (attachment).
USE
OF
PRESCREENED LISTS
In the event the credit union board of directors authorizes key staff to participate in “prescreening” we understand
our obligation to provide notices to consumers consisting of an initial, prominent statement that provides the basic
opt-out information, followed by a separate longer explanation that provides additional details. If direction to
“prescreen” transpires, we will refer to NCUA Part 717 and Parts 642 and 698 of FTC regulations, and implement
appropriate written procedures as necessary.
(“Prescreening” involves submitting a request to a CRA for the contact information of consumers meeting certain preestablished criteria that will be reflected in the CRA’s records, such as credit scores in a certain range. The CU then sends offers
of credit targeted to those consumers).
ADDRESS DISCREPANCIES
If the credit union receives a Notice of Address Discrepancy from a credit reporting agency we will confirm an
address is accurate by:
 Contacting the member
 Reviewing the member file and compare information in the consumer report to credit union information
 Utilizing third party resources, such as collection agency, card processor
 If warranted, the credit union will enhance the CIP procedure by requesting additional verification of
identity from this member.
Loan proceeds cannot be disbursed or closed until the CEO or credit committee chairperson has reviewed the
Notice of Address Discrepancy and follow–up, and can ascertain with reasonable certainty that the report belongs
to the member/borrower.
At which time the credit union has reasonably confirmed the address is accurate, we will furnish the address to the
CRA as part of the information the credit union regularly furnishes.
DISPOSAL OF RECORDS
In an effort to protect the privacy of member information and reduce the risk of fraud and identity theft, the credit
union will take appropriate measures to dispose of sensitive information derived from consumer reports.
The CEO will determine the disposal method based on the sensitivity of the information, the current cost and
benefit of different disposal methods, and changes in technology, on condition that one of the following disposal
practices are exercised:
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Burn, pulverize, or shred papers containing consumer report information so that the information cannot be
read or reconstructed;
Destroy or erase electronic files or media containing consumer report information so that the information
cannot be read or reconstructed;
Conduct due diligence and hire a document destruction contractor to dispose of material specifically identified
as consumer report information consistent with the Rule.
 Should the credit union decide to outsource disposal of records to a vendor, due diligence will include,
at a minimum:
 Reviewing an independent audit of a disposal company’s operations and/or its compliance
with the Rule;
 Obtaining information about the disposal company from several reliable references;
 Obtaining assurance that the disposal company possesses the required certifications or
licenses; and
 Reviewing and evaluating the disposal company’s information security policies or procedures.
NOTICE
TO HOME LOAN APPLICANTS AND CREDIT SCORE DISCLOSURE
When utilizing credit scores In connection with both open-end and closed-end purchase money mortgages,
refinanced loans, home equity loans, second mortgages, and home equity lines of credit secured by 1 to 4 units of
residential real property, we will provide the “Notice to Home Loan Applicant and Credit Score Disclosure”
(attachment). The notice and score disclosure shall be provided as soon as reasonably practical, but no later than
the loan closing if the loan is approved, or along with the adverse action notice if the loan is denied.
The Notice to Home Loan Applicant and Credit Score notice shall be included on the credit union’s mortgage loan
and home equity loan checklist. A loan will not be closed unless all disclosures have been provided to the member,
and noted on the checklist. The mortgage officer will be responsible for ensuring proper handling of the notices.
PROTECTION
OF MEDICAL INFORMATION
The credit union may obtain and use medical information pertaining to a member in connection with
any determination of the member’s eligibility, or continued eligibility, for credit, as long as:
 The information relates to debts, expenses, income, benefits, collateral, or the purpose of the loan, including
the use of proceeds;
 We use the information in a manner and to an extent no less favorable than we would use comparable
information that is not medical information in a credit transaction; and
 We do not take the member’s physical, mental, or behavioral health, condition or history, type of treatment,
or prognosis into account as part of any credit eligibility determination.
RISK-BASED PRICING NOTICE
Effective July, 2011, the Federal Reserve Board (Board) and the Federal Trade Commission (FTC) issued final rules
to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer
Protection Act. If a credit score is used in setting material terms of credit, the statute requires creditors to
disclose credit scores and related information to consumers in notices under the Fair Credit Reporting Act (FCRA).
The CEO with assistance from the lending manager is responsible for implementing and complying with the riskbased notice requirement. The credit union will provide a risk-based pricing notice to members that receive credit
on terms materially less favorable than terms offered to most members based in whole or in part on a consumer
report. The rule allows the credit union several methods for determining which members/applicants must receive
risk-based pricing notices. In addition, the rule allows for certain exceptions to the notice requirement, as such the
credit union will examine the best method at least annually.
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Consumer-to-Consumer Comparison – this involves comparing each applicant to an adequate sample of
members who are offered a specific type of credit, such as vehicle loans or student loans.
Credit score proxy method – under this method the credit union must give notices to each applicant that falls
in the bottom 60% of credit scores
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Tiered pricing method – under this approach the credit union may place the applicant within one of a discrete
number of pricing tiers based on a consumer report. The only factor to consider is tiers with different APRs. A
notice must be sent to those applicants who do not qualify for the top (lowest-priced) tier for a four or fewer
tier system, or the top two tiers for a five or more tier system, as well as additional tiers that comprise
between 30-40% of the total number of tiers.
GUIDELINES
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Members that do not receive the best rate offered in the credit union’s credit card program will receive a
notice
The credit union will implement the same notice determination method for a specific type of credit product.
However, the method may vary among different loan products
Risk-based pricing notices will only be given to those who receive materially less favorable terms and not to
all members who apply for credit.
Notices need not be given to guarantors, co-signers, sureties, or endorsers or those who are offered credit but
decline it before the notice is provided.
If the credit union conducts a periodic account review and increases a member’s annual percentage rate
based in whole or in part on a credit report, we will provide either an account review notice or adverse action
notice to the member.
For closed-end credit, the notice will be provided before the loan agreement is in force.
For open-end credit, the notice will be provided before the first transaction is made.
For account reviews, the notice will be provided no later than five days after the effective date of the APR
change.
For indirect auto lending, the requirement to provide a risk-based pricing notice is satisfied if the auto dealer
provides a notice to the member on the credit union’s behalf within the required time periods. The CEO or
lending manager is responsible for evaluating the dealer relationship to ensure reasonable policies and
procedures are in place.
The credit union is not required to provide risk based pricing notices:
o If a member applies for a specific loan product and receives the terms associated with that product
o If a member is provided an adverse action notice
o If the credit union obtains a consumer report that is a prescreened list and uses that consumer report
to make a firm offer of credit to consumers.
o When an extension of credit is or will be secured by one to four units of residential real property and
the consumer is provided a notice consisting of his credit score and certain additional information.
ALTERNATIVE TO THE RISK-BASED PRICING NOTICE
The risk based pricing notice is NOT required if the credit union opts to provide a credit score disclosure. To use
this alternative the credit union must provide a credit score disclosure to ALL members who apply for credit, unlike
the risk-based pricing notice, which is only provided to members who receive less than favorable terms.
The credit score disclosure must be provided as soon as reasonably practicable after the credit score is obtained,
but before the member is obligated for the credit transaction.
The credit score disclosure must include the member's credit score the source of the score, the date the score was
created, and the range of possible scores. In addition, the credit score disclosure must tell the member how his or
her credit score compares to the scores of other consumers using a short narrative statement or a bar graph. The
credit score disclosure also informs the consumer of the right to request a free annual credit report from each of
the three nationwide credit bureaus, along with contact information (attached).
ACCURACY
AND INTEGRITY OF INFORMATION
The credit union shall strive to protect the privacy of credit report information and guarantee that information
supplied to consumer reporting agencies (CRAs) is as accurate as possible, and in doing so, the credit union, as
furnishers of information to CRA’s, will adhere to the following:
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INFORMATION REPORTING
The credit union will not furnish information that we know — or consciously avoid knowing — is inaccurate.
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CORRECTING AND UPDATING INFORMATION
If we discover we supplied one or more CRAs with incomplete or inaccurate information, key staff will correct
credit union’s records as appropriate, resubmit to each CRA, report only the correct information in the future,
and notify the member of such action.
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MEMBER - NOTICE OF DISPUTE
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If a member notifies the credit union and challenges the accuracy of any information we furnished to a
CRA, the credit union will inform the member that he/she must complete a direct dispute notice
(attachment).
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Upon receiving a completed “Notice of Dispute”, key staff will investigate the dispute and review all
relevant information. Within 30 days a written determination to the member will be provided.
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If the information is, in fact, inaccurate, we will report the correct information to the CRA(s), with a copy
to the member.
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If a member has given notice that he or she disputes information, we will not report information to any
CRA without also informing the CRA that the information is in dispute.
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The credit union WILL NOT investigate anything having to do with the member’s identifying information,
identity of past employers, inquiries, information derived from public records fraud or active duty alerts,
information provided by another furnisher, or direct disputes submitted by credit repair organizations.
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If the credit union determines that a dispute is frivolous (such as, those that contain insufficient
information or those that are substantially similar to previous disputes from the same member), we will
provide the member with a written explanation within 5 days of the determination date.
CONSUMER REPORTING AGENCY – NOTICE OF DISPUTE
If a CRA notifies the credit union that a member disputes information we provided, we will, within 30 days of
the notice:
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Investigate the dispute and review all relevant information provided by the CRA about the dispute.
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Report our findings to the CRA and the member, and if the investigation establishes that the information
was incomplete or inaccurate, we will report the results to the member and all CRAs to which the credit
union provided the information.
REPORTING ACCOUNTS CLOSED BY THE MEMBER
Recognizing that other users may interpret a closed account as an indicator of bad credit, the credit union will
ensure that the CRA is notified, either in writing or through our third-party provider, that the member - not
the credit union, closed the credit account.
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REPORTING DELINQUENT ACCOUNTS
If the credit union reports information about a delinquent account that’s placed for collection, charged off, or
subject to any similar action, we will, within 90 days after we report the information, notify the CRA of the
month and the year that the delinquency began. This will ensure that the CRA uses the correct date when
computing how long derogatory information can be kept in the members credit file.
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PROCEDURES
The guidelines set forth below will provide additional assurances that the accuracy and integrity of the
information we furnish to consumer reporting agencies is correct.
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In the event a third party provider is used for the purpose of submitting information to a CRA, the CEO will
be responsible for ensuring that the vendor is compliant with FACT ACT requirements. Further,
confirmation will be obtained that the communication methods used to transmit data to a CRA is
designed to prevent duplicative reporting of accounts, erroneous association of information with the
wrong consumer, and other occurrences that may compromise the accuracy or integrity of information
provided to CRAs.
To the extent possible, the credit union will submit information to a CRA electronically, via an approved
vendor. Transmission of information about members will transpire monthly and in a standardized format
suitable for reporting to a CRA.
The lending staff is responsible for furnishing accurate information to the credit bureau, whether via
vendor agreement or manually.
The teller staff is responsible for furnishing accurate information to ChexSystems, whether via vendor
agreement or manually.
If the credit union participates in any transfer of accounts process (such as mergers, portfolio acquisitions
or sales), the lending manager or key staff will review any CRA reports prior to submission to prevent reaging of information, duplicate reporting, or other problems that may affect the accuracy and integrity of
information furnished to CRAs.
Key staff will obtain appropriate training to carry out the requirements of this policy.
Key staff will report all member disputes to the Supervisory Committee,
The Supervisory Committee will be responsible for periodic inspection of information key staff provides to
consumer reporting agencies. In addition, the supervisory committee will review completed member
dispute investigations periodically, and a detailed report of all findings presented to the board at least
annually.
RECORD RETENTION
With the intention of substantiating the accuracy of any information the credit union furnishes that is subject
to a direct dispute, we will maintain records in accordance with all applicable regulations.
PREVENTION
OF RE-POLLUTION
If the credit union receives either a notice from a consumer reporting agency or a member regarding identity theft,
key staff will complete an investigation and notify the CEO of the results. If required, the CEO will take the steps
necessary to block information from reaching a CRA. If the account is a share account, the account in question will
be closed and a new account opened.
NOTICE
OF NEGATIVE
INFORMATION
The credit union will provide written notice to a member if we furnish information to a consumer reporting agency
related to delinquency, late payments, insolvency, or any form of default.
If the notice is provided prior to furnishing the negative information to the CRA, the notice will include the
following statement:
We may report information about your account to credit bureaus. Late payments, missed payments, or
other defaults on your account may be reflected in your credit report.
If the credit union provides a notice after furnishing the negative information, we will do so within 30 days and the
notice will include the following statement:
We have told a credit bureau about a late payment, missed payment or other default on your account.
This information may be reflected in your credit report.
ID THEFT “RED FLAGS” PREVENTION PROGRAM
(Source: Carol Bertoux, ICUL GC, Federal Trade Commission, NCUA, and CUNA)
After consideration of the size and complexity of the credit union’s operations and the nature and scope of our
activities, we constructed the following Identity Theft Prevention Program to help detect, prevent and mitigate
identity theft.
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The program is intended to provide credit union staff with the tools needed to effectively recognize and manage
attempted and actual identity theft in connection with all “covered accounts” accounts (share/savings,
checking/draft, auto loans, mortgage, personal loans, credit card accounts, etc.) and related operations.
Because identity theft is an ever-changing threat, we will re-evaluate our program periodically.
RISK ASSESSMENT
To effectively address the threat of identity theft the credit union will conduct a risk assessment by considering the
risk factors in identifying red flags relevant to the credit union, as indicated below:
The types of accounts offered include:
Share
Draft
Certificates
Club Money Market
Prepaid Cards
Debit Card
Credit Card
Personal Loan /Consumer
HELOC Mortgage
Other______________
Other______________
Other______________
The types of account-opening methods allowed include:
Online
Phone
Mail
In-Person
The means of access to accounts Include:
Online
Phone
Mail
In-Person
Bill-Pay
Debit
Wire Transfer
Other______________
Other______________
Other______________
Check/Draft
Credit Card
Debit Card
ATM
Other______________
Other______________
Other______________
The credit union’s previous experiences with identity theft include:
Unauthorized use or attempted use of existing credit cards
Unauthorized use or attempted use of other existing accounts such as checking accounts
Misuse of personal information to obtain new accounts or loans, or to commit other crimes
Other____________________________________________________________________________________
Other____________________________________________________________________________________
Other____________________________________________________________________________________
In consideration of the foregoing, the following red flags are potentially relevant to this Credit Union’s
operations:
Alerts, notifications, or other warnings from consumer reporting agencies or service providers, including:
Fraud or active duty alerts included with a consumer report.
Consumer reporting agency notices of a credit freeze in response to a request for a consumer report.
Consumer reporting agency notices of an address discrepancy.
Consumer reports indicating a pattern of activity that is inconsistent with the history and usual pattern of activity
of an applicant or member, such as:
A recent and significant increase in the volume of inquiries;
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An unusual number of recently established credit relationships;
A material change in the use of credit, especially with respect to recently established credit relationships;
or
An account that was closed for cause or identified for abuse of account privileges.
Presentation of suspicious documents, such as:
ID documents that appear to have been altered or forged.
Photos or physical descriptions on identification that are not consistent with the appearance of the person
presenting the identification.
Other information on identification is not consistent with information provided by the person presenting the
identification.
Other information on identification is not consistent with readily accessible information that is on file with the
credit union, such as a signature card or a recent check.
Applications that appear to have been altered or forged, or give the appearance of having been destroyed and
reassembled.
Presentation of suspicious personal identifying information, such as:
Personal identifying information provided is inconsistent when compared against external information sources.
For example:
The address does not match any address in the consumer report; or
The SSN has not been issued, or is listed on the Social Security Administration's Death Master File.
Personal identifying information provided by the member is not consistent with other personal identifying
information provided by the member. For example, there is a lack of correlation between the SSN range and date of
birth.
Personal identifying information provided is associated with known fraudulent activity as indicated by internal or
third-party sources. For example:
The address on an application is the same as the address provided on a fraudulent application; or
The phone number on an application is the same as the number provided on a fraudulent application.
Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated
by internal or third-party sources. For example:
The address on an application is fictitious, a mail drop, or prison; or
The phone number is invalid, or is associated with a pager or answering service.
The SSN provided is the same as that submitted by other persons opening an account or other members.
The address or telephone number provided is the same as or similar to the account number or telephone number
submitted by an unusually large number of other persons opening accounts or other members.
The person opening the account fails to provide all required personal identifying information on an application or
in response to notification that the application is incomplete.
Personal identifying information provided is not consistent with personal identifying information that is on file
with the credit union.
For credit unions that use challenge questions, the person opening the account cannot provide authenticating
information beyond that which generally would be available from a wallet or consumer report.
Unusual Use of, Suspicious Activity related to an account, such as
Shortly following the notice of a change of address, receipt of a request for a new, additional, or replacement
card or for the addition of authorized users on the account.
A new revolving credit account is used in a manner commonly associated with known patterns of fraud. For
example:
The majority of available credit is used for cash advances or merchandise that is easily convertible to
cash (e.g., electronics equipment or jewelry)
The member fails to make the first payment or makes an initial payment but no subsequent payments
An account is used in a manner that is not consistent with established patterns of activity on the account. There
is, for example:
Nonpayment when there is no history of late or missed payments
A material increase in the use of available credit
A material change in purchasing or spending patterns
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A material change in electronic fund transfer patterns
An account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the
type of account, the expected pattern of usage and other relevant factors)
Mail sent to the member is returned repeatedly as undeliverable although transactions continue to be conducted
The credit union is notified that the member is not receiving paper account statements
The credit union is notified of unauthorized charges or transactions
Notices of possible ID theft regarding a credit union account -- from members, a victim of identity theft, law
enforcement, or others – stating that the credit union has opened a fraudulent account for a person engaged in
identity theft.
DETECTION OF RED FLAGS
The following are in place to help detect the above Red Flags:
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Compliance with the Credit Union’s Patriot Act Identity Verification Program.
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The Credit Union’s requirements for authentication regarding remote transaction or signatures:
Two-factor authentication
Other___________________________
VPN security
Other___________________________
Web authentication
Other___________________________
 Sign on protections
Other___________________________
 Identity and access protection
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The following software monitoring functions:
Firewall protection
Use of most current operating system
Use of most current web browser
Use up-to-date virus protection software
Prohibit downloading from unknown sources
Scan for infected files often
Allow use of secure sites only (those that
include an image of a padlock in the lower right
corner of the internet browser and an “s”
following the “http” portion of the internet
address).
Guard user names and passwords.
Change passwords often
Encryption
Secure Sockets Layer
Digital Signature
Random Number Generation
Secure Multipurpose Internet Mail Extensions
Password Usage and Generation
Other___________________________
Other___________________________
Other___________________________
Other__________________________
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Address change validation requirements that must be followed before a change of address is implemented
o Verifying the address with the member;
o Reviewing its own records to verify the address of the member
o Verifying the address through third-party sources; or using other reasonable means
PREVENTION AND MITIGATION OF IDENTITY THEFT
Whenever a Red Flag is detected, the Credit Union will undertake one or more of the following responses to
thwart the fraud, depending on the factual situation, [as determined by senior management]:
 Monitoring the account for evidence of identity theft;
 Contacting the member for verification, authentication, or notice, as applicable;
 Changing passwords, security codes, or other security devices that permit access to an account;
 Re-opening an account with a new account number;
 Not opening a new account;
 Closing an existing account;
 Not attempting to collect on an account;
 Notifying law enforcement; or
 Determining that no response is warranted under the particular circumstances.
 When there is an indication of a data security breach, the required notice will be given, and all accounts
possibly involved will be monitored;
 When the Credit Union has received notice that a member has provided account information to a phisher, the
account will be monitored for a period of 90 days.
 Decline to effect an address change, extend additional credit, or provide services related to the red flag until
identity is confirmed.
STAFF TRAINING
Staff will initially undergo training to implement the Program, and thereafter as needed regarding updates or as a
refresher course.
DESIGNATION OF PERSON RESPONSIBLE FOR PROGRAM OVERSIGHT
The CEO is responsible for implementation of this Program, monitoring for compliance, and approval of material
changes as necessary to address changing identity theft risks.
COMPLIANCE REPORTS
Staff of the credit union responsible for aspects of the Program will report on compliance at least annually -- to the
Board of Directors
Reports will address:
 The effectiveness of the policies and procedures of the credit union in addressing the risk of identity
theft;
 Service provider arrangements;
 Significant incidents involving identity theft and management's response; and
 Recommendations for material changes to the Program.
THIRD-PARTY SERVICE PROVIDER OVERSIGHT
Whenever a third-party service provider is utilized to administer any aspect of this Program, the Credit Union will
take steps to ensure that the activity of the service provider is conducted in accordance with reasonable policies
and procedures designed to detect, prevent, and mitigate the risk of identity theft.
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In part, the Credit Union will require the service provider, by contract, to have policies and procedures in place to
detect relevant Red Flags that may arise in the performance of the service provider's activities -- and to either
report the Red Flags to the credit union or take appropriate steps to prevent or mitigate identity theft. (Attached)
The credit union will take appropriate steps to ensure that the activity of all service providers is conducted in
accordance with reasonable policies and procedures designed to detect, prevent, and mitigate the risk of identity
theft (attachment).
The credit union will make every effort to obtain, in potential contracts, an assurance by the service provider to
have policies and procedures to detect relevant Red Flags that may arise in the performance of the service
provider’s activities, and either report the red flags to the credit union, or to take appropriate steps to prevent or
mitigate identity theft.
PROGRAM UPDATES
The CEO is authorized to update the Program to reflect changes in risks to members or to the safety and
soundness of the credit union. The following events may require an update in the Program:
 Experiences of the credit union with identity theft;
 Changes in methods of identity theft;
 Changes in methods to detect, prevent, and mitigate identity theft;
 Changes in the types of accounts that the credit union offers or maintains; and
 Changes in the business arrangements of the credit union (e.g., mergers, acquisitions, alliances, joint
ventures, and service provider arrangements).
Updates will be reported to the Board as changes take place.
RULES FOR DEBIT/CREDIT CARD ISSUERS
The credit union will not issue, or make a request to issue, any additional or replacement credit or debit cards if
such a request is received within 30 days after receiving notification of a change of address for that account, unless
the credit union does the following:
 Notifies the cardholder of the request at the cardholder’s former address; or by any other means of
communication that the credit union and the cardholder have previously agreed to use.
 Provides to the cardholder a reasonable means of promptly reporting incorrect address changes; or
otherwise assesses the validity of the change of address in accordance with credit union policy.
Any written notice that the credit union provides to verify a change of address will be provided separately from its
regular correspondence with the member
OTHER APPLICABLE LEGAL REQUIREMENTS
The credit union will be mindful of other related legal requirements that may be applicable, such as:
 Filing a Suspicious Activity Report under the Bank Secrecy Act;
 Implementing any requirements under the Fair Credit Reporting Act (FCRA), regarding the circumstances
under which credit may be extended when the credit union detects a fraud or active duty alert.
 Implementing any requirements for furnishers of information to consumer reporting agencies under the
FCRA. For example, to correct or update inaccurate or incomplete information, and to not report
information that the furnisher has reasonable cause to believe is inaccurate; and
 Complying with the FCRA prohibition on the sale, transfer, and placement for collection of certain debts
resulting from identity theft.
INFORMATION AVAILABLE TO VICTIMS
The credit union will provide victims of identity theft copies of any records related to a fraudulent activity
transacted at the credit union within 30 days of the request.
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Model Form and Procedures for Identity Theft Victims
The credit union will provide and promote the location of the model form and procedures – Take Charge: Fighting
Back Against Identity Theft. This guidance includes the ID theft affidavit and sample letters as well as a description
of the circumstances under which victims would use a particular form to contact creditors or consumer reporting
agencies. The booklet is available at www.consumer.gov/idtheft or by writing to: FTC, Consumer Response Center,
Room 130-B, 600 Pennsylvania Avenue, N.W. Washington, D.C., 20580.
MEMBER EDUCATION
As part of our overall effort to address the problem of identity theft the credit union will provide our members
with the resources they need to arm themselves against identity theft. Primarily, we will rely on the suite of
materials provided by the Federal Trade Commission (FTC).
FREE ANNUAL CREDIT REPORTS
In an effort to help our members avoid confusing “free” offers of consumer reports, we will be steadfast in our
efforts to remind them that while they have the right to a free credit report – there is but ONE authorized source
under federal law. AnnualCreditReport.com or 877-322-8228.
SHARING
INFORMATION WITH AFFILIATES
The credit union does not share any eligibility information - both transactional information and information that would
normally be considered a “consumer report” with any affiliates (any company related by common ownership, typically a CUSO
controlled by credit unions).
Under the affiliate marketing rules, the credit union understands that if we share certain information with an affiliated entity
(CUSO), the affiliate cannot use that information to make a solicitation for marketing purposes unless the consumer is:

Provided a notice that the information may be used for marketing

Given reasonable opportunity to “opt-out” of these solicitations; and

The consumer does not “opt-out”
If and when necessary, the credit union will refer to NCUA and FTC rules for guidance
TRUNCATION
OF CREDIT/DEBIT CARD ACCOUNT NUMBERS
If the credit union accepts credit cards or debit cards for the transaction of business, we will not print more than
the last 5 digits of the card number or the expiration date upon any electronically printed receipt provided to the
cardholder at the time of transaction. This will not apply to transactions in which the sole means of recording a
credit card or debit card account number is by handwriting or by an imprint or copy of the card.
PROGRAM/POLICY
APPROVED BY
-
REVISION DATES
Board approved
____________________________________________
Origination Date:
____________________________________________
Last Amended Date
_____________________________________________________
Next Review Date
_______________________________________________
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Adverse Action Notice (sample 1)
Sample Notice of Action Taken and Statement of Reasons Statement Credit Denial, Termination or
Change (page 1 of 2) (rev. 2011).
____________________________
_________________________________
_________________________________
_________________________________
Dear__________________________:
The following represents notification of adverse action, including detailed information regarding credit
denial, termination or change. If you have any questions regarding this notice, please contact the credit
union at (____) ________________.
Description of Account, Transaction, or Requested Credit:
____________________________________________________________________________________
Description of Action Taken:
____________________________________________________________________________________
Principal Reason(s) for Credit Denial, Termination, or Other Action Taken Concerning Credit:
Credit application incomplete
Unable to verify income
Insufficient number of credit references provided
Length of residence
Unacceptable type of credit references provided
Temporary residence
Unable to verify credit references
Unable to verify residence
Temporary or irregular employment
No credit file
Unable to verify employment
Limited credit experience
Length of employment
Poor credit performance with us
Income insufficient for amount of credit requested
Bankruptcy
Excessive obligations in relation to income
Collection action or judgment
Garnishment or attachment
Number of recent inquiries on credit bureau report
Foreclosure or repossession
Delinquent past or present credit obligations with
others
Value or type of collateral not sufficient
Other, specify:
(continued…)
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Page 14 of 31
Disclosure of Use of Information Obtained From an Outside Source
Our credit decision was based in whole or in part on information obtained in a report from the consumer reporting
agency listed below. You have a right under the Fair Credit Reporting Act to know the information contained in your credit
file at the consumer reporting agency. The reporting agency played no part in our decision and is unable to supply
specific reasons why we have denied credit to you. You also have a right to a free copy of your report from the reporting
agency, if you request it no later than 60 days after you receive this notice. In addition, if you find that any information
contained in the report you receive is inaccurate or incomplete, you have the right to dispute the matter with the reporting
agency, as indicated below:
 Experian
PO Box 2104
Allen, TX 75013
(888) 397-3742
www.experian.com
 Equifax
PO Box 740241
Atlanta, GA 30374
(800) 685-1111
www.equifax..com
 TransUnion
PO Box 2000
Chester, PA 19022
(800) 888-4213
www.transunion.com
If you have any questions regarding this letter, you should contact us at :
________________________________________________________
________________________________________________________
Telephone Number ________________________________________
We also obtained your credit score form this consumer reporting agency and used it in making our credit decision. Your
credit score is a number that reflects the information in your consumer repot. Your credit score can change, depending
on how the information in your consumer report changes.
Your credit score: _____________________
Date: _______________________________
Scores range from a low of _______________ to a high of _______________
Key factors that adversely affected your credit score:
1.
________________________________________________________
2.
________________________________________________________
3.
________________________________________________________
4.
________________________________________________________
5.
________________________________________________________
If you have any questions regarding your credit score, you should contact the entity that provided the credit score
(consumer reporting agency), as indicated above.
Notice: The federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit
applicants on the basis of race, color, religion, national origin, sex, marital status, age (provided the
applicant has the capacity to enter into a binding contract); because all or part of the applicant's income
derives from any public assistance program; or because the applicant has in good faith exercised any
right under the Consumer Credit Protection Act. The federal agency that administers compliance with this
law concerning this creditor is ___________________________________________________________.
⃝ Federal Credit Unions: National Credit Union Administration, Office of Consumer Protection (OCP), Division of
Compliance and Outreach (DCCO), 1775 Duke Street, Alexandria, VA 22314.
⃝ State Credit Unions: Federal Trade Commission, Equal Credit Opportunity, Washington, DC 20580
Consumer
Credit Union
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Page 15 of 31
MEMBER NOTICE DISPUTING CREDIT UNION INFORMATION SUBMITTED TO A CONSUMER REPORTING AGENCY.
Please complete and return this form (along with any supporting documentation) and mail to:
________________________________________________________
________________________________________________________
________________________________________________________
Upon receipt of your dispute, the credit union will investigate your dispute and provide you with a written
determination of our findings within 30 days of the date we receive your dispute.
MEMBER INFORMATION
Date
Requested:
Member Name:
Member
Address:
Account No.
E-Mail Address:
Date of Birth
Phone
Last 4 digits of
SS number
DL number
XXX – XX - _____ _____ _____ _____
DETAILS
Please provide details on why you are disputing information the credit union provided to the consumer
reporting agency.
Indicate the details in the space provided below
NOTE – Attach all supporting documentation that you think might be helpful in the resolution of your
dispute.
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Page 16 of 31
AMENDMENT TO AGREEMENT
BETWEEN __________________________ CREDIT UNION (“Credit Union”) and
___________________________________________________ (“Service Provider”)
WHEREFORE, on
, an agreement was entered into between
______________________________________________ services (the “Agreement”).
the
parties
for
WHEREFORE, certain laws require that the Agreement be amended to add confidentiality and identity theft
prevention and mitigation provisions.
NOW, THEREFORE, the parties agree as follows:
1.
The parties hereby amend the Agreement by adding the following paragraphs:
Notwithstanding other Agreement provisions to the contrary, it is understood and agreed that member and
customer information obtained pursuant to this Agreement will be held in strict confidence and used only as
necessary to provide Agreement services, or where otherwise required or permitted by law. Access to
member and customer information will be limited to those employees and agents needing such information to
provide Agreement services, and pursuant to reasonable business practices adopted to limit access and
unauthorized disclosure of same.
Service Provider represents that it has in place policies and procedures to detect relevant identity theft red
flags that may arise in the performance of the Service Provider’s activities. Service Provider further agrees to
notify Credit Union in the event of a data security breach or other detection of relevant identity theft red flags
and to take appropriate steps to prevent or mitigate identity theft.
This confidentiality and identity theft prevention and mitigation provision shall survive termination of the
Agreement.
2.
All other provisions of the Agreement remain in full force and effect.
3.
This amendment is effective this _________ day of ____________________, 200___.
___
CREDIT UNION
_____________________________________
By:___________________________________
By:__________________________________
Typed Name:___________________________
Typed Name:__________________________
Typed Title:____________________________
Typed Title:___________________________
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Page 17 of 31
Risk-Based Pricing Notice (rev. 2013) - for use in complying with the general risk-based pricing notice
requirements if a credit score is not used in setting the material terms of credit
_________________________________________________________________Credit Union
Your Credit Report and the Price You Pay for Credit
What is a credit report?
How did we use your credit
report[s]?
A credit report is a record of your credit history. It includes information
about whether you pay your bills on time and how much you owe to
creditors.
We used information from your credit report[s] to set the terms of the
credit we are offering you, such as the [Annual Percentage Rate/down
payment].
The terms offered to you may be less favorable than the terms offered to
consumers who have better credit histories
You have a right to dispute any inaccurate information in your credit
report[s].
What if there are mistakes in your
credit report[s]?
If you find mistakes on your credit report[s], contact:
______________________________________________________
which is the consumer reporting agency from which we obtained your
credit report.
It is a good idea to check your credit report[s] to make sure the
information it contains is accurate.
Under federal law, you have the right to obtain a copy of your credit
report[s] without charge for 60 days after you receive this notice. To
obtain your free report[s], contact:______________________________
How can you obtain a copy of your
credit report(s)?
By telephone: Call toll-free: 1-877-_____ ________
By mail: Mail your written request to:
___________________________________________________________
On the web: Visit www. __________
How can you get more information
about credit reports?
js//ICUL-FACTact
For more information about credit reports and your rights under federal
law, visit the Consumer Financial Protection Bureau’s website at
www.consumerfinance.gov/learnmore
Page 18 of 31
Risk-based Pricing Notice with Credit Score Information (page 1 of 2)(rev. 2013) for use in complying with
the general risk-based pricing notice requirements if a credit score is used in setting the material terms of credit
_________________________________________________________________Credit Union
Your Credit Report and the Price You Pay for Credit
What is a credit report?
How did we use your credit
report[s]?
A credit report is a record of your credit history. It includes information
about whether you pay your bills on time and how much you owe to
creditors.
We used information from your credit report[s] to set the terms of the
credit we are offering you, such as the [Annual Percentage Rate/down
payment].
The terms offered to you may be less favorable than the terms offered to
consumers who have better credit histories
You have a right to dispute any inaccurate information in your credit
report[s].
What if there are mistakes in your
credit report[s]?
If you find mistakes on your credit report[s], contact:
______________________________________________________
which is the consumer reporting agency from which we obtained your
credit report.
It is a good idea to check your credit report[s] to make sure the
information it contains is accurate.
Under federal law, you have the right to obtain a copy of your credit
report[s] without charge for 60 days after you receive this notice. To
obtain your free report[s], contact:______________________________
How can you obtain a copy of your
credit report(s)?
By telephone: Call toll-free: 1-877-_____ ________
By mail: Mail your written request to:
___________________________________________________________
On the web: Visit www. __________
How can you get more information
about credit reports?
js//ICUL-FACTact
For more information about credit reports and your rights under federal
law, visit the Consumer Financial Protection Bureau’s website at
www.consumerfinance.gov/learnmore
Page 19 of 31
Risk-based Pricing Notice with Credit Score Information (page 2 of 2)
Your Credit Score and Understanding Yo
Your Credit Score
Understanding Your Credit Score
What you should know about credit scores
How we use your credit score
The range of scores
30%
Key
Factors
that
adversely
affected
your
credit
score
1.
________________________________________________________
2.
________________________________________________________
3.
________________________________________________________
25%
20%
15%
10%
5%
4.
5.
________________________________________________________
_________________________________________________________
0%
0100
201300
How can you get more information about your credit score?
js//ICUL-FACTact
Page 20 of 31
401500
No Credit Score Notice – (rev. 2013) for use in connection with the credit score disclosure exception when
no credit score is available for the consumer
_________________________________________________________________Credit Union
Credit Scores and the Price You Pay for Credit
Your Credit Score
Your Credit Score
What you Should know
about your credit scores
Why credit scores are
important
Your credit score is not available from _______________________which is a
consumer reporting agency, because they may not have enough information about
your credit history to calculate a score.
A credit score is a number that reflects the information in a credit report.
A credit report is a record of your credit history. It includes information about
whether you pay your bills on time and how much you owe to creditors.
A credit score can change, depending on how a consumer’s credit history changes.
Credit scores are important because consumers who have higher credit scores
generally will get more favorable credit terms.
Not having a credit score can affect whether you can get a loan and how much you
will have to pay for that loan.
Checking Your Credit Report
What if there are
mistakes in your credit
report?
You have a right to dispute any inaccurate information in your credit report. If you
find mistakes on your credit report, contact the consumer reporting agency.
It is a good idea to check your credit report to make sure the information it contains is
accurate.
Under federal law, you have the right to obtain a free copy of your credit report from
each of the nationwide consumer reporting agencies once a year.
To order your fee annual credit report –
By telephone: Call toll-free 1-877-322-8228
How can you obtain a
copy of your credit
report(s)?
On the web: Visit www.annualcreditreport.com
By mail: Mail you completed Annual Credit Report Request Form (which you can
obtain from the Federal Trade Commissions’ web site at:
http://www.ftc.gov/bcp/conline/include/requestformfinal.pdf to:
Annual Credit Report Request Service
P.O. Box 105281
Atlanta, GA 30348-5281
How can you get more
information?
js//ICUL-FACTact
For more information about credit reports and your rights under federal law, visit the
Consumer
Financial
Protection
Bureau’s
website
at
www.consumerfinance.gov/learnmore
Page 21 of 31
Account Review Risk-based Pricing Notice- (rev. 2013) for risk-based pricing notices given in connection with
account review if a credit score is not used in increasing the annual percentage rate.
_________________________________________________________________Credit Union
Your Credit Report and the Pricing of Your Account
What is a credit report?
How did we use your credit
report[s]?
What if there are mistakes in your
credit report[s]?
A credit report is a record of your credit history. It includes information
about whether you pay your bills on time and how much you owe to
creditors.
We have used information from your credit report[s] to review the terms
of your account with us.
Based on our review of your credit report[s], we have increased the
annual percentage rate on your account.
You have a right to dispute any inaccurate information in your credit
report[s].
If you find mistakes on your credit report[s], contact:
______________________________________________________
which is the consumer reporting agency from which we obtained your
credit report.
It is a good idea to check your credit report[s] to make sure the
information it contains is accurate.
Under federal law, you have the right to obtain a copy of your credit
report[s] without charge for 60 days after you receive this notice. To
obtain your free report[s], contact:______________________________
How can you obtain a copy of your
credit report(s)?
By telephone: Call toll-free: 1-877-_____ ________
By mail: Mail your written request to:
___________________________________________________________
On the web: Visit www. __________
How can you get more information
about credit reports?
js//ICUL-FACTact
For more information about credit reports and your rights under federal
law, visit the Consumer Financial Protection Bureau’s website at
www.consumerfinance.gov/learnmore
Page 22 of 31
Account Review Risk-based Pricing Notice with Credit Score Information (page 1 of 1) (rev. 2013) - for
risk-based pricing notices given in connection with account review if a credit score is used in increasing the annual
percentage rate
_________________________________________________________________Credit Union
Your Credit Report and the Pricing of Your Account
What is a credit report?
How did we use your credit
report[s]?
What if there are mistakes in your
credit report[s]?
A credit report is a record of your credit history. It includes information
about whether you pay your bills on time and how much you owe to
creditors.
We have used information from your credit report[s] to review the terms
of your account with us.
Based on our review of your credit report[s], we have increased the
annual percentage rate on your account.
You have a right to dispute any inaccurate information in your credit
report[s].
If you find mistakes on your credit report[s], contact:
______________________________________________________
which is the consumer reporting agency from which we obtained your
credit report.
It is a good idea to check your credit report[s] to make sure the
information it contains is accurate.
Under federal law, you have the right to obtain a copy of your credit
report[s] without charge for 60 days after you receive this notice. To
obtain your free report[s], contact:______________________________
How can you obtain a copy of your
credit report(s)?
By telephone: Call toll-free: 1-877-_____ ________
By mail: Mail your written request to:
___________________________________________________________
On the web: Visit www. __________
How can you get more information
about credit reports?
js//ICUL-FACTact
For more information about credit reports and your rights under federal
law, visit the Consumer Financial Protection Bureau’s website at
www.consumerfinance.gov/learnmore
Page 23 of 31
Account Review Risk-based Pricing Notice with Credit Score Information (page 2 of 2)
Your Credit Score and Understanding Yo
Your Credit Score
Understanding Your Credit Score
What you should know about credit scores
How we use your credit score
The range of scores
30%
Key
Factors
that
adversely
affected
your
credit
score
1.
________________________________________________________
2.
________________________________________________________
3.
________________________________________________________
25%
20%
15%
10%
5%
4.
5.
________________________________________________________
_________________________________________________________
0%
0100
201300
How can you get more information about your credit score?
js//ICUL-FACTact
Page 24 of 31
401500
Form for Credit Score Disclosure Exception for Loans not Secured by Residential Real Property (page
1 of 2)
For use in connection with the credit score disclosure exception for loan that are not secured by residential real property
(rev. 2013)
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Page 25 of 31
________________________________________________________________
Your Credit Report and the Price You Pay for C
Your Credit Score
Your Credit Score
Understanding Your Credit Score
What you should know about credit scores
How we use your credit score
% of Consumers with Scores in a Particular Range
The range of scores
js//ICUL-FACTact
100%
90%
80%
70%
60%
30%
50%
25%
40%
20%
30%
15%
20%
10%
10%
5%
0%
0%
Score Range
0-100
101-200 201-300
301-400 401-500
501-600
0100
Page 26 of 31
201300
401500
Credit Score Disclosure Exception for Loans Not Secured by Residential Real Property (page 2 of 2)
Checking Your Credit Report
You have the right to dispute any inaccurate information in your credit report. If you
What if there are
find mistakes on your credit report, contact the consumer reporting agency.
mistakes in your credit
report?
It is a good idea to check your credit report to make sure the information it contains is
accurate.
Under federal law, you have the right to obtain a free copy of your credit report from
each of the nationwide consumer reporting agencies once a year.
To order your free annual credit reportBy telephone: Call Toll-free 1-877-322-8228
How can you obtain a
copy of your credit
report(s)?
On the web: Visit www.annualcreditreport.com
By mail: Mail your completed Annual Credit Report Request Form (which you can
obtain
from
the
Federal
Trade
Commission’s
web
site
at
http://www.ftc.gov/bcp/conline/include/requestformfinal.pdf to:
Annual Credit Report Request Service
P.O. Box 105281
Atlanta, GA 30348 -5281
How can you get more
information about
credit reports?
js//ICUL-FACTact
For more information about credit reports and your rights under federal law, visit the
Consumer
Financial
Protection
Bureau’s
website
at
www.consumerfinance.gov/learnmore
Page 27 of 31
Form for Credit Score Disclosure Exception for Loans Secured by Residential Real Property (page 1 of
2)
For use in connection with the credit score disclosure exception for loans secured by residential real property (Rev. 2013)
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Page 28 of 31
_________________________________________________________________Credit Union
Your Credit Report and the Price You Pay for C
Your Credit Score
Your Credit Score
Understanding Your Credit Score
What you should know about credit scores
How we use your credit score
% of Consumers with Scores in a Particular Range
The range of scores
js//ICUL-FACTact
100%
90%
80%
70%
60%
30%
50%
25%
40%
20%
30%
15%
20%
10%
10%
5%
0%
0%
Score Range
0-100
101-200 201-300
301-400 401-500
501-600
0100
Page 29 of 31
201300
401500
Credit Score Disclosure Exception for Loans Secured by Residential Real Property (page 2 of 2)
Understanding Your Credit Score
1.__________________________________________________________________
Key factors that
adversely affected your
credit score
2.__________________________________________________ ________________
3.___________________________________________________________________
4.___________________________________________________________________
5.___________________________________________________________________
Checking Your Credit Report
You have the right to dispute any inaccurate information in your credit report. If you
What if there are
find mistakes on your credit report, contact the consumer reporting agency.
mistakes in your credit
report?
It is a good idea to check your credit report to make sure the information it contains is
accurate.
Under federal law, you have the right to obtain a free copy of your credit report from
each of the nationwide consumer reporting agencies once a year.
To order your free annual credit reportBy telephone: Call Toll-free 1-877-322-8228
How can you obtain a
copy of your credit
report(s)?
On the web: Visit www.annualcreditreport.com
By mail: Mail your completed Annual Credit Report Request Form (which you can
obtain
from
the
Federal
Trade
Commission’s
web
site
at
http://www.ftc.gov/bcp/conline/include/requestformfinal.pdf to:
Annual Credit Report Request Service
P.O. Box 105281
Atlanta, GA 30348 -5281
How can you get more
information
about
credit reports?
js//ICUL-FACTact
For more information about credit reports and your rights under federal law, visit the
Consumer
Financial
Protection
Bureau’s
website
at
www.consumerfinance.gov/learnmore
Page 30 of 31
Notice To The Home Loan Applicant
In connection with your application for a home loan, the lender must disclose to you the score that
a consumer reporting agency distributed to users and the lender used in connection with your home loan,
and the key factors affecting your credit scores.
The credit score is a computer generated summary calculated at the time of the request and
based on information that a consumer reporting agency or lender has on file. The scores are based on
data about your credit history and payment patterns. Credit scores are important because they are used
to assist the lender in determining whether you will obtain a loan. They may also be used to determine
what interest rate you may be offered on the mortgage. Credit scores can change over time, depending
on your conduct, how your credit history and payment patterns change, and how credit scoring
technologies change.
Because the score is based on information in your credit history, it is very important that you
review the credit-related information that is being furnished to make sure it is accurate. Credit records
may vary from one company to another.
If you have questions about your credit score or the credit information that is furnished to you,
contact the consumer reporting agency at the address and telephone number provided with this notice, or
contact the lender, if the lender developed or generated the credit score. The consumer-reporting agency
plays no part in the decision to take any action on the loan application and is unable to provide you with
specific reasons for the decision on a loan application.
If you have questions concerning the terms of the loan, contact the credit union at ___________.
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