Compliance Q&A: Record Keeping Requirements for Prescreened Credit Offers
Q: What are the record keeping requirements for prescreened credit offers?
A: Section 615(d)(3) of the Fair Credit Reporting Act requires anyone who makes a prescreened credit offer to maintain the following records for three years, beginning on the date the offer was made to the consumer:
- The criteria used to select the consumer to receive the offer;
- All criteria bearing on creditworthiness that are the basis for determining whether to extend the credit offer; and
- Any requirement for collateral as a condition of extending the offer.
In addition, Regulation B (Equal Credit Opportunity Act) requires credit unions to retain copies of prescreened credit solicitations for 25 months after the date on which an offer of credit was made to potential borrowers (Sec. 1002.12(b)(7)).