FR 2021-03914

The document published by the National Credit Union Administration (NCUA) outlines their intention to submit an information collection request to the Office of Management and Budget (OMB) as required by the Paperwork Reduction Act of 1995. This submission concerns the Fair Credit Reporting Act (FCRA), which details how consumer credit information should be managed. The Fair Credit Reporting Act has evolved over the years through amendments like the Dodd-Frank Wall Street Reform and Consumer Protection Act, transferring some responsibilities to the Consumer Financial Protection Bureau (CFPB), while others remain with the NCUA. The publication invites public comments to be submitted by March 29, 2021.

General Summary

This Federal Register announcement serves to inform the public of a process that affects credit unions, particularly regarding compliance with the Fair Credit Reporting Act. The Act governs the collection, dissemination, and use of consumer credit information, significant for any financial institution's operations. The document highlights different roles between the CFPB and NCUA in regulating this. The public is encouraged to provide feedback on the proposed collection, aligning with standard practices for transparency and accountability in federal regulatory processes.

Significant Issues and Concerns

There are several areas in the document that could benefit from enhanced clarity:

• Burden Hours: The document states an estimated total of 272,686 annual burden hours related to the information collection. However, it does not detail how this figure was calculated, which may obscure understanding for interested stakeholders.

• Regulatory Specifics: Specific provisions, such as Parts 1022 and 717, are referenced without explanation of their impact on individuals or organizations involved, potentially leading to confusion.

• Complex Legislative Language: The discussion of the Dodd-Frank Act and its implications for consumer protection laws could be challenging for laypeople to comprehend without additional explanation.

• Use of Jargon: Terms like "identity theft red flags" are not defined in the document, which might make it difficult for those unfamiliar with related regulatory language to understand.

• Triggers for Information Collection: While specific events prompt information collection under the relevant regulations, the document does not specify what these events are, creating ambiguity around compliance expectations.

Impact on the Public

Broadly, the document signifies regulatory processes that ensure financial institutions adhere to established standards for managing consumer credit information, which indirectly assures protections for consumers. It keeps the public informed of an opportunity to contribute input on potential regulatory impacts affecting their interactions with credit unions.

Impact on Specific Stakeholders

• Credit Unions: As major stakeholders, credit unions are directly affected by changes in regulatory requirements. Compliance with evolving FCRA regulations might require adjustments in their information processing systems and strategies for identity theft prevention.

• Consumers: The document symbolizes efforts to protect consumer credit data integrity, although lack of clarity in certain areas could make it difficult for average consumers to understand how these changes directly benefit or affect them.

• Regulatory Bodies: NCUA retains certain regulatory responsibilities under the FCRA, ensuring their role remains significant in managing industry standards. At the same time, collaboration with the CFPB ensures comprehensive consumer protection coverage.

Overall, while this regulatory notice is routine in nature, it is essential for maintaining transparency and engaging public dialogue in regulatory practices, albeit the complexities involved necessitate clearer communication for broader understanding.