Question & Answer

Question: I work for a national bank. The new adverse action forms in Regulation B include some address changes to our forms. Do we have to destroy the old forms even if they contain the new language for the Fair Credit Reporting Act?

Answer: You can expect your National Bank Examiner to be reasonable on this one. The regulatory agencies are pretty good at forwarding mail - especially consumer complaints - to the new location. You should be able to use up your current supply of notices without criticism from OCC.

If you choose to use up the old forms, make sure that whoever will place the order to reprint knows that the form needs updating. While you update the form, take the time to review the other compliance requirements. If you want to recommend changes - such as a rewording of reasons for adverse action - this would be the best time.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 10, 7/98