Employers Should Use New FCRA Disclosure Notice

By: Anne E. Baggott

Employers should immediately begin using a revised Fair Credit Reporting Act notice form to applicants during the adverse-action process.  Failure to use the updated form, or a substantially similar form, could subject employers to costly class-action lawsuits and potential liability for non-compliance. The new notice requirements were effective September 21, 2018.

The Bureau of Consumer Financial Protection issued a model summary of rights disclosure notice in response to a May 2018 law passed to address high-profile data breaches.  The revised model form includes information about security freezes and fraud alerts.  The revised form can be found at www.consumerfinance.gov/about-us/newsroom/bureau-consumer-financial-protection-issues-updated-fcra-model-disclosures/

Contact Anne Baggott at abaggott@dysarttaylor.com or 816-931-2700 for more information regarding compliance with the FCRA.

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