Over the past two months, the Federal Trade Commission (FTC) and banking agencies have continued to push through the massive regulatory rulemaking requirements under the FACT Act. Whether or not all of the rulemakings will be completed by the statutory deadlines remains anyone's guess. The past month, the FTC released its study on Credit Report Accuracy and Access to Credit. AFSA commented on the methodology behind this study. See below for a link to both the study and AFSA's comments.

The FTC and banking agencies continue to work on the Affiliate Marketing Rule. Comments on their proposed rule were due on August 16. AFSA submitted comments on behalf of its members and eagerly awaits seeing the final version of the rule. Please see below for a link to both the proposed rule and AFSA's comments.

Some sections of the FACT Act did not require rulemaking. The fraud alerts, furnishing negative information and the duty of furnishers to provide information are just three of the fifteen sections the industry must comply with by December 1, 2004 or else face potential liability.

Despite the progress of the agencies, major rulemakings still remain. Section 311 of the FACT Act, the section on Risk-Based Pricing, has not yet been released.

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