Anthony LaFaziaCEO, Atlantic Training · CEO at Atlantic Training | EdTech & Safety Compliance Leader

Notice Requirements Under the FCRA: What to Include and When to Send It

1 Jul 2026 · 2 min

Watch on YouTube

2:19

In this instructional video, Speaker A outlines the Fair Credit Reporting Act (FCRA) notice timing obligations for various credit products. For closed‑end credit such as mortgages and auto loans, the notice must be delivered before consummation—i.e., before the borrower signs the contract—so the consumer can address any reporting errors before being bound to a long‑term loan. For open‑end credit like credit cards and home‑equity lines of credit, the notice must be included in the account‑opening package and received before the first transaction is made. Auto dealers face a similar pre‑consummation rule, but they must also take reasonable steps to ensure the consumer actually receives the notice rather than burying it in paperwork. Finally, Speaker A advises that Exception Notices (used when a consumer disputes a report after the loan application) should be sent as soon as reasonably practicable, not delayed. Speaker B interjects with a promotional read for Atlantic Training and Wave HR software, which is unrelated to the compliance content.

Chapters

Okay, so we know who gets it. Now let's talk about when. In compliance, a day late is a dollar short. The timing depends on what kind of credit you're slinging. First, there's closed-end credit. Talkin' mortgages, auto loans. The notice must be provided before consummation. Consummation is just a fancy word for signing the dotted line. The customer needs to see this notice before they're legally bound. If they see their scores tanked because of an error, they need a chance to pause before signing a 5-year contract at a high rate.
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Second is the open-end credit. We're talking credit cards, HELOCs. You have to provide the notice before the first transaction's made. Usually this means it gets tucked into the account opening package, but it has to be there before they swipe that card for the first time. Thirdly, you've got auto dealers. Pay attention. The timing's similar, before consummation. But you've got to make sure the consumer actually receives it. Don't just bury it in a stack of papers. Point it out. Now look, if you're using the Exception Notice, that's the one we just talked about, providing it as soon as reasonably practicable after taking the loan application is generally the best practice. Don't sit on it.