AFIP Fair CreditAFIP公平信用.pdfVIP

Association of Finance Insurance Professionals AFIP CERTIFIED FI PROFESSIONAL BASIC SENIOR COURSE R e q u i r e d S u p p l e m e n t a l Tr a i n i n g w i t h Q u i z Adverse Action notice requirements as mandated by The Equal Credit Opportunity Act and the Fair Credit Reporting Act THIS SUPPLEMENT IS PROVIDED AS AN INDUSTRY SERVICE BY: READ THIS FIRST TO: Basic Senior AFIP Certified FI Professionals FROM : David Robertson – Executive Director SUBJECT: FI Procedure Changes – Mandated Training The FTC has indicated it intends to enforce the adverse action notification requirements of the Fair Credit Reporting Act (“FCRA”) more vigorously than in the past. This supplement provides a review of the FCRA and the related Equal Credit Opportunity Act (“ECOA”) and the procedures dealership personnel must follow to ensure compliance. This information is drawn from the National Automobile Dealers Association’s (NADA’s) A Dealer Guide to Adverse Action Notices and from material compiled by the law firm of Hudson Cook, LLP. In addition to the review, this supplement provides appendices with sample forms and a 25-question quiz. AFIP recommends that dealerships use NADA’s simplified Adverse Action Notice form included as Appendix B.* The other sample Notices, which also are set forth in the NADA guide, are taken directly from regulations issued by the Federal Reserve Board. You must comply with the law every time a customer’s request for credit is denied. The required procedures are not the result of new legislation or FTC policy, but are in recognition of the fact that the existing notification rules imposed by the FCRA are not always being met in the pr