Monthly Regulatory Compliance Change Management Summary

You will find our monthly Regulatory Compliance Change Management Summary as of April 30, 2018, here.

Noteworthy Items:

West Virginia SB 563 (§46A-2-128(f)) –  The statute of limitations to file legal action for the collection of debt is 10 years, not 5 years, as previously reported in last month’s Monthly Regulatory Compliance Change Management Summary.

The following disclosure must be included in all written communication once the loan has been delinquent for more than 10 years:

• 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.

As a reminder, if you provide Cenlar privacy policies to be sent to borrowers you will need to include this language on the notice.

New Items:

Furnisher Data and Reporting – Effective September 15, 2017, furnishers of newly opened trade and collection data must report the full name (First, Middle, Last Name and Generation Code/Suffix), address, full Social Security Number and Date of Birth (mmddyyyy).

This new minimum standard applies to accounts reported with a Date Opened after the effective date of September 15, 2017, in order for the CRAs to accept these records for processing.

Please note with this new requirement Date of Birth is now necessary on all newly boarded or transferred loans. 

This month’s Regulatory Compliance Change Management conference call will take place on Wednesday, May 16 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).

Best regards,

Nancy Irwin

Vice President Client Relations

609-883-3900 ext. 2551