Because of compliance costs, credit unions should have at least an additional six months to meet requirements for disclosing credit scores when letting members know the prices of certain products, CUNA wrote the Federal Reserve.
In a comment letter on proposed regulations regarding risk-based notifications for consumers, CUNA said the delay was needed because of the many compliance requirements stemming from last year’s regulatory overhaul bill. The regulations are supposed to take effect on July 21.
CUNA Regulatory Counsel Dennis Tsang also wrote that his association hopes that the order of the content on a model notice does not change; and the credit union shouldn’t have to present the credit score information before the credit report information.
Tsang praised the Fed for clarifying in the proposal that a creditor may continue to provide a credit score exception notice instead of a risk-based pricing notice, and that creditors won’t have to provide a credit score if it uses information from a credit report that does not include a credit score.
Also, the regulation doesn’t require the creditor provide the borrower with the credit score of a guarantor or endorser.
