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Creditors and Employers Beware: CFPB Amends Model Background Check Form and Adverse Action Language

March 21st, 2023 by David Anthony, Chris Capurso, David Gettings, Ethan Ostroff, Tim St. George, Alan Wingfield @www.consumerfinancialserviceslawmonitor.com

The Consumer Financial Protection Bureau (CFPB or Bureau) issued a final rule updating, among other things, the model form for the Fair Credit Reporting Act (FCRA) Summary of Consumer Rights and information that must be included in adverse action notices under the Equal Credit Opportunity Act (ECOA). Specifically, the CFPB is correcting the contact information in the Summary of Consumer Rights model form for multiple federal agencies (including the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC)), updating references to obsolete business types, and making other technical corrections.

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