Proposed Changes to the FACT Act

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FACTA 312a: Accuracy and Integrity of Information Furnished to Credit Reporting Agencies

Posted 1/29/09

NCUA has a proposed regulation 717 parts 41 through 43 to address many of the recommended changes to the FACT Act. This is a proposed regulation, not one currently in effect. However, we encourage you to review this regulation (see the link below) to understand what might be required in the future, paying special attention to Appendix E.

There does seem to be some confusion as the information we are hearing from clients does not match up with the actual requirements. This proposed section outlines the credit union's responsibilities for (1) monitoring the accuracy of the information sent to the credit bureaus and (2) ensuring that service providers are conducting this task in a secure manner.

(1) CU*BASE allows you to see all member data reported to the credit bureaus, under the standard Metro II format, by simply using Account Inquiry to view a member loan account (use the F23-Delq/Cr Rpt Hist function). You can view the data and determine at any point in time if the account was reported correctly. Your review procedures could be as simple as reviewing a sampling of accounts on an annual basis to determine the accuracy of the reporting. You can also print the Credit Bureau Information Report (MNRPTE #13) to see all loan data sent to credit bureaus.

You may also want to review your Loan Purpose Codes configuration (MNCNFB #3). Purpose Codes contain the credit reporting loan type, so make sure these are being used properly by your loan staff.

(2) To answer the latter part of this requirement, CU*Answers transmits all data electronically to all the major credit bureaus through an encrypted data transmission.

Again, if you are concerned with the accuracy of credit reporting and what MAY be required in the future, please review the proposed regulation, available on the NCUA website.

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