The Federal Financial Institution Examinations Council (FFIEC) Task Force on Consumer Compliance has approved the attached revised Fair Credit Reporting Act (FCRA) examination procedures, which incorporate the new requirements created by the Fair and Accurate Credit Transactions Act of 2003 (FACT Act).
The revised FCRA examination procedures have been reorganized into a new format in which similar requirements are grouped into modules for use in risk-focused compliance examinations. This modular format is also designed to assist financial institutions in organizing compliance programs and internal reviews. The revised procedures separate background information from the examination steps, contained in Appendix A. Appendix B lists the statutory and regulatory requirements in the order in which they are addressed in the examination procedures, according to a financial institution's primary federal regulator.
The revised procedures are effective immediately and will be used during compliance examinations conducted by the FDIC beginning on the date of issuance of this FIL. The scope of examiners' policy and procedures review and transaction testing will be tailored to an institution's operations and risks identified in the overall assessment of the institution's compliance risk profile.
Questions about the FCRA examination procedures may be directed to David Lafleur, Policy Analyst-Compliance, at dlafleur@fdic.gov or (202) 898-6569, or John Jackwood, Senior Policy Analyst-Compliance, at jjackwood@fdic.gov or (202) 898-3991.
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Sandra L. Thompson
Acting Director
Division of Supervision and Consumer Protection |