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Adverse Action
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Adverse Action requirements created
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Must send all reports to consumer whether or not using a CRA within 7 days
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Return to Adverse Action requirements – removes requirement of sending all reports to consumers
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Disclosure
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Required at any time prior to requesting a background report. It must state that a report "may" be requested.
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Required within 3 days of request of a background report. It must state that a report has been ordered, except when there is wrongdoing.
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Required at any time prior to requesting a background report. It must state that that a report "may" be requested, except when there is wrongdoing or misconduct.
When using a CRA, your disclosure must have a box the consumer may check to request a copy of the report. When not using a CRA, if you access public records, your employment application must have a box the consumer may check to request a copy of the report.
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Required Language on Reports
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N/A
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Cover page must have warning disclosure in 16-point type.
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Cover page must have a reduced warning disclosure in bold 12-point type.
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Permissible Purpose
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·Court order or subpoena
·Written instructions by the consumer who is the subject of the report
·Credit
·Employment
·Insurance Underwriting
·Investor, Servicer, Insurer of existing credit obligation
·Legitimate Business Need
oBusiness Transaction initiated by the consumer
oFor account review to confirm terms are met
·Child support enforcement
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N/A
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More
restrictive language between CRA’s and Users of reports helps to reduce
identity theft and potentially eliminate the “get anything on anybody”
websites.
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