Compliance

Compliance Q&A: Branch Office Closures

Must CUs go through a specific process before permanently closing branch offices?

January 13, 2012
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Q Does the credit union have to provide a negative information notice each time a member is late with a payment on the same loan account?

A No. The credit union doesn’t have to provide the notice each time a member is late with a payment on the same loan account.

The Fair Credit Reporting Act only requires that the credit union provide the negative information notice to the member prior to, or no later than, 30 days after furnishing the negative information to a nationwide consumer reporting agency.

After providing the notice, the credit union may submit additional derogatory information to the credit bureau with respect to the same transaction, extension of credit, account, or individual without providing additional notice to the member.

Credit unions that provide the notice to members before furnishing the negative information to credit bureaus would disclose: “We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.”

Credit unions that provide the notice to members after furnishing the negative information to credit bureaus would disclose: “We have told a credit bureau about a late payment, missed payment, or other default on your account. This information may be reflected in your credit report.”

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