Permissible Purpose & No Other Purpose

Last week, I received a letter from my credit union stating: “Because of your excellent credit record we’re increasing the limit on your credit card.” This got me thinking about whether the institution had a permissible purpose to review my credit. Section 604 of the Fair Credit Reporting Act requires that credit bureaus (credit reporting agencies, or CRAs) must have … Read More

Fair Credit Reporting Act Disclosures and Indirect Automobile Lending

Credit unions should either retain copies of provided Risk Based Pricing Notices in loan files or perform due diligence on automobile dealers to confirm they are providing the notices in a timely manner to the credit union’s indirect borrowers. The Division of Credit Unions released Bulletin B-16-04 providing guidance for state-chartered credit unions on indirect lending compliance requirements – specifically … Read More