| Date: | Tuesday, July 29, 2008 |
| Time:* | 1:00 PM – 2:30 PM ET |
| Featured Speaker: | Jonathan D. Jerison |
| Duration: | 90 Minutes |
| Location: | Your office or conference room |
| Prerequisites: | None |
If your area does NOT observe Daylight Saving Time, the time will be one hour earlier.
The Federal Reserve Board and Federal Trade Commission just issued proposed rules that will revise the Fair and Accurate Credit Transactions Act and will require all lenders to provide a notice to consumers who are offered an interest rate that is significant higher than the existing rate. New Risk-Based Pricing Notice Rule: How FCRA Will Change will explore key developments regarding the Fair Credit Reporting Act and will analyze how the new rule will affect lending and financial institutions.
Program Highlights Include:
- Risk-Based Pricing
- Will the final rule contain as much flexibility as the proposal?
- For example, will it allow use of a generic notice? Will it apply only to higher interest rates (as the proposal does) or also to other unfavorable terms?
- Which alternative is best for my institution – a generic, upfront notice to all consumers or transaction-specific notices to those offered higher prices?
- E.g., do we want to give upfront notices to our prime customers who would probably never receive a transaction-specific notice?
- Can brokers give the generic notice on behalf of lenders?
- The rule indicates that the initial creditor is responsible for giving the notice. Does this mean that only a table-funding broker can give the notice?
- FACTA Affiliate-Marketing Rule
- Effective 10/1/08
- Will we have to send out updated notices?
- Do we have to shut down our common database if we don’t send new notices?
- Alternatives to following the new rules
- How does “constructive sharing” (where the institution with the customer relationship sends out the solicitation) work? Does the solicitation have to be on the sharing institution’s letterhead?
- Litigation and Legislative Developments
- Is the FCRA litigation boom over?
- Have recent court decisions and legislation put an end to “firm-offer” and “credit card truncation” cases?
- How do Safeco and Radian affect other types of FCRA litigation?
- Where are we still exposed to FCRA litigation?
Registration Includes:
- Admittance to the 90-minute call for as many people as you can fit in a room with a speakerphone
- Access to the specially created presentation handouts (made available 48 hours in advance) which can be printed and used to train your personnel
- Participation in a 30-minute live Q&A with the speaker following the presentation
- Certificates of completion for all audio conference attendees
About Our Speaker
Jonathan D. Jerison provides regulatory, legislative and transactional advice to lenders and servicers. He counsels financial institutions and their affiliates on complying with federal and state consumer protection laws and regulations; including providing general regulatory advice, providing advice on fair lending issues, reviewing consumer disclosures, drafting legislative or regulatory language or advocacy papers, and advising on electronic commerce matters. Mr. Jerison holds a J.D. degree from the University of California School of Law, an M.L.T. from Georgetown University, and a B.A. from Yale University. Jon is a frequent speaker at financial industry conferences and seminars.