In July 2010, the Dodd-Frank Wall Street Reform and Consumer Protection Act was signed into law and the Consumer Financial Protection Bureau (CFPB) was given the authority to enforce the Fair Credit Reporting Act. (Prior to this, the Federal Trade Commission held the primary enforcement authority over the FCRA.) The CFPB has implemented mandates to the required (per FCRA) applicant authorization forms for background checks. These required text changes must be implemented by January 1, 2013.
- A Summary of Your Rights Under the FCRA: (This document is optionally provided to applicants prior to the background check and always provided to an applicant when taking Pre-Adverse Action.)
- Notice to Users of Consumer Reports: (This document states the obligations of users under the FCRA and should be kept on file by each of our clients.)
The main difference in these forms is that the CFBP is now listed as the contact for FCRA related information, as opposed to the Federal Trade Commission.