Update Forms to Reference CFPB

CUs must update certain model forms to reference the new federal agency.

November 30, 2012

Credit unions must update certain model forms to reference the Consumer Financial Protection Bureau (CFPB).

That’s because the Dodd-Frank Act transferred rule-making authority for a number of consumer financial protection laws from seven federal agencies to the CFPB.

Make sure forms providers are on top of making the necessary revisions to provide you with updated forms by Jan. 1, 2013.

The changes involve:

► Regulation B (Equal Credit Opportunity Act—ECOA) adverse action notices. The handful of credit unions with more than $10 billion in total assets must amend forms to list the CFPB as the agency that administers ECOA compliance.

What about all other credit unions? State charters don’t need to make a technical correction. Continue to list the Federal Trade Commission. Federal credit unions must list NCUA’s Office of Consumer Protection on these forms.

 Reg V (Fair Credit Reporting Act). Update risk-based pricing model forms to reference CFPB’s website.

 Reg Z (Truth in Lending Act). Change references to the CFPB from the Federal Reserve Board on all credit card applications and solicitations model forms G-10(A) through G-10(C), and credit card account-opening model forms G-17(A) through G-17(C).

More information on these regulatory changes is available on CUNA’s e-Guide to Federal Laws and Regulations (cuna.org and select “regulations & compliance”).