Monthly Regulatory Compliance Change Management Summary

You will find our monthly Regulatory Compliance Change Management Summary as of March 2018 here.

Noteworthy Items:

West Virginia SB 563 (§46A-2-128(f)) –  Effective July 4, 2017, this legislation requires that a disclosure is included in all written communications with the consumer when the debt is beyond the statute of limitations to file legal action for collection of the debt. The statute of limitations to file legal action for the collection of debt is 5 years.  At the 7 year point, the second disclaimer should be used because that is the point that the FCRA limits negative credit reporting to the bureaus.

The following disclosures must be included in all written communication:

5 year disclosure

NOTICE TO WV CONSUMERS – The law limits how long you can be sued on a debt. Because of the age of your debt, (INSERT OWNER NAME) cannot sue you for it. If you do not pay the debt, (INSERT OWNER NAME) may report or continue to report it to the credit reporting agencies as unpaid.

7 year disclosure

NOTICE TO WV CONSUMERS – The law limits how long you can be sued on a debt. Because of the age of your debt,  (INSERT OWNER NAME) cannot sue you for it and (INSERT OWNERS NAME) cannot report it to any credit reporting agencies.

Please note if you provide Cenlar privacy policies to be sent to borrowers you will need to include this language on the notice.

This month’s Regulatory Compliance Change Management conference call will take place on Thursday, April 26 at 3pm EST. To register for the call, please email compliancechgmngt@cenlar.com. For your convenience, the call will be recorded for distribution to clients who are unable to attend.

Any questions related to the monthly summary, overview process, or specific regulatory change items can be sent directly to compliancechgmngt@cenlar.com and the Compliance Department will respond within one business day of receipt (excluding weekends and holidays).