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Course description

The Fair Credit Reporting Act limits the circumstances under which a consumer reporting agency may furnish a consumer report.   Therefore, creditors and anyone else who is a user of consumer reports must understand the allowable purposes for which consumer reports may be obtained and the privacy implications of obtaining consumer reports for impermissible purposes.  


In addition to the permissible purposes that are enumerated under the act, there is a history of interpretations on the meaning of “permissible purpose” under different circumstances and scenarios. There is also a number of court cases that tell an interesting story about the current privacy concerns over use of consumer reports.  


In this one-hour webinar we will:


  • Review the basics of the FCRA permissible purposes requirements, including the circumstances under which it is permissible for a consumer reporting agency to furnish a consumer report
  • Discuss the sometimes controversial question of whether you need to get the customer’s written authorization to obtain a consumer report when there is an application for credit 
  • Cover the use of consumer reports for employment purposes. While “employment” is a permissible purpose under the FCRA, there are certain additional conditions on obtaining consumer reports for employment purposes and we will review those additional conditions and disclosures that are required when a consumer report is used in connection with employment
  • Review the use of consumer reports for account review and other uses after a consumer account has been opened
  • Review some of the recent litigation that addresses permissible purpose 



Who Should Attend:   Compliance officers, marketing staff, auditors, lenders, human resources, new accounts, branch staff who take application



Nancy Derr-Castiglione

Nancy Derr-Castiglione is the owner of D-C Compliance Services, which is a regulatory compliance consulting firm for banks and other financial services companies that was launched in January 2002. Nancy is a Certified Regulatory Compliance Manager (CRCM) and has been since 1991. Nancy has over 43 years of regulatory compliance experience, starting as an assistant national bank examiner with the Office of the Comptroller of the Currency in the Consumer Compliance Division. She has worked in all aspects of compliance management for banks, including United Banks of Colorado (now Wells Fargo), Cherry Creek National Bank (now American National Bank), and Bank One (now Chase Bank). D-C Compliance Services provides a variety of compliance services for clients, including Bank Secrecy Act/Anti-Money Laundering independent reviews, compliance training, loan and deposit regulatory audits, compliance management assessments, fair lending risk assessments and audits, development of policies and procedures and overall risk management programs, and specialized projects relating to regulatory actions. Nancy has been active in the American Bankers Association for many years, has written extensively on compliance matters, spoken at conferences and webinars, and served on many professional committees. She is currently the Executive Editor of the ComplianceAction newsletter. She was the 2001 recipient of the ABA Distinguished Service Award.

Course curriculum

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