New Credit Score Disclosures: New Amendments to Regs B and V


Presented by: Jack Holzknecht and Mary Beth Guard

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If a credit score is used in setting material terms of credit or in taking adverse action, the statute requires creditors to disclose credit scores and related information to consumers in notices under the Fair Credit Reporting Act (FCRA).

The final rules amend:
  • Regulation V (Fair Credit Reporting) to revise the content requirements for risk-based pricing notices, and to add related model forms that reflect the new credit score disclosure requirements.
  • Certain model notices in Regulation B (Equal Credit Opportunity), which combine the adverse action notice requirements for Regulation B and the FCRA, to reflect the new credit score disclosure requirements.
The revised rules will be effective sometime in early- to mid-August.

Failure to comply with adverse action requirements can lead to civil liability and enforcement actions from the regulators.

Upon completion of this program your staff will understand:
  • The revisions to the risk-based pricing notices in regulation V, including:
  • New model risk-based pricing notices;
  • Whether use of the revised risk-based pricing notice is required if the creditor has chosen to provide credit score exception notices;
  • When a creditor is deemed to be "using" a credit score; and
  • Whether a risk-based pricing notice must be provided to a co-signer or guarantor;
  • The revised rules for adverse action forms in Regulation B including:
  • New model adverse action forms;
  • Who should receive an adverse action notice when a credit application involves multiple applicants;
  • Whether the credit score of a guarantor or a co-signer should be disclosed to the applicant, where the creditor uses the credit score of the guarantor or the co-signer in taking adverse action;
  • Which credit score is disclosed when a creditor obtains multiple credit scores from consumer reporting agencies in connection with their underwriting processes; and
  • Whether credit score information must be disclosed in FCRA adverse action notices for non-lending products, such as a deposit account, insurance product, or employment.
The program is designed for compliance officers, auditors and for those with responsibility for assuring compliance throughout the lending department.

About the Speakers: Mary Beth Guard currently serves as Executive Editor of and CEO of Glia Group, Inc. Mary Beth has had a long and distinguished career, graduating from law school in 1980. She has focused her work exclusively on the banking industry since 1984. Previously, Mary Beth served as EVP/General Counsel and COO for the Oklahoma Bankers Association, EVP of Specialized Services for Thomson Financial Publishing, and General Counsel for the Oklahoma State Banking Department.

Mary Beth is one of the founders of and She maintains an active speaking schedule and has written many articles relating to compliance and other banking topics. She is a BOL Guru.

Jack Holzknecht is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced consultant who has provided training to thousands of bankers and examiners for twenty-nine years. He has the ability to identify the key compliance issues from each regulation. Jack's career began in 1976 as a federal bank examiner. He later headed the form and software and education divisions of a regional consulting company. In that capacity he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by the Georgia, Iowa, Kentucky, Pennsylvania, Nebraska, New York and Texas bankers associations. He developed and delivered compliance training for the FDIC and OTS for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a "BOL Guru" at

This program was recorded in its entirety in August 2011. The CD-ROM includes program slides, materials (if available) and follow-up Q & A document.

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  • Model: cd_regbv0811
  • Manufactured by: Glia Group, Inc.

This product was added to our catalog on Monday 11 July, 2011.

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