Today we revised our employee screening disclosures and service agreements. This was done in advance of the mandatory requirement, effective January 1, 2013, that these employee screening disclosures, as well as the FCRA Summary of Rights be updated.
The reason that these revisions are being required is because the Consumer Financial Protection Board (CFPB) is replacing the Federal Trade Commission (FTC), as the chief enforcer of the Fair Credit Reporting Act (FCRA).
It should be noted that there are no substantive changes in the regulations of the FCRA, but rather the name and contact information for the CFPB is replacing the contact information of the FTC, as the governing enforcement agency for FCRA regulations.
Even though no substantive changes to FCRA regulations have occurred, it is mandatory that these new disclosures be used no later than January 1. 2013. However, we are advising our clients to begin using these new disclosures immediately to have ample time to implement the revised forms prior to the mandatory January 1, 2013 implementation date.
Posted by: Rudy Troisi. President, Reliable Background Screening.