Both the ECOA Notice (Cx1413) and Statement of Credit Denial, Termination or Change (Cx15858) are primarily provided pursuant to the provisions of ECOA and Regulation B (12 CFR § 1002.9[a] & [b][1]). The text of Cx1413 is set forth in 12 CFR § 1002.9(b)(1), while Cx15858 is a copy of Sample Form C-1 found in 12 CFR Pt. 1002, App. C.
Both documents must disclose “the name and address of the Federal agency that administers compliance with respect to the creditor.” (12 CFR § 1002.9[a][2]; see also Ibid. § 1002.9[b][1]). A list of such agencies and their addresses are set forth under 12 CFR Pt. 1002, App. A, as well as instructions as to which should be listed based on the type of creditor providing the forms.
In the past, clients have had to customize the text of these documents to print the appropriate information. We are happy to announce that we have created a new field (“Adverse Action – Federal Regulatory Agency”; Field # 109187) which will populate this information on the forms, thus enabling clients to select the information as they see fit.
Agencies (and their corresponding contact information) which can be listed are as follows:
- CFPB
- CFPB and FTC
- OCC
- FED (aka FRB)
- FDIC
- NCUA
- FTC
Clients are encouraged to review Appendix A, determine which one of these options is appropriate for their business, and set Field # 109187 appropriately. Note that we do not support all the agencies listed in Appendix A, since none of our clients are supervised by such agencies (e.g. the Department of Transportation).
These changes will be in effect on February 24, 2017. If you have any questions or concerns about these changes, please contact Client Support at 1.800.497.3584.
DR 219554