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We are updating all of our forms to include references to the CFPB. Do we need to update the Federal Trade Commission (FTC) Identity Theft Brochure? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We are updating all of our forms to include references to the CFPB. Do we need to update the Federal Trade Commission (FTC) Identity Theft Brochure?

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While the Dodd-Frank Act did transfer some of the rulemaking authority under the Fair Credit Reporting Act (FCRA) to the CFPB, including some of the identity theft provisions, we do not believe that the FTC’s identity theft brochures will be updated to include references to the CFPB. Even after the Dodd-Frank Act, the FTC remains the primary source of information on identity theft for consumers. 

The most recent versions of the FTC’s brochures are available here: http://www.ftc.gov/bcp/edu/microsites/idtheft/become-a-partner.html

Also, the customer notice required by the Interagency Guidelines Establishing Information Security Standards, which should include the FTC’s contact information, has not been updated with the CFPB’s contact information — again, the FTC remains the primary contact for identity theft resources.