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Today,  the Federal Trade Commission published in the Federal Register a notice of rescission of its commentary and interpretive rulings to its rules under the Fair Credit Reporting Act.  The Commission stated that the rescission was based primarily upon the fact that the commentary was “stale” and, in some cases, even in conflict with current law.  The FTC’s rule making and enforcement authority for the FCRA was transferred to the Consumer Financial Protection Bureau (CFPB) on July 21, 2011.  It will now be up to the CFPB to issue guidance and interpretations on the rules, and credit unions should no longer rely upon guidance previously issued by the Commission.  The Association will let credit unions know when the CFPB issues any such guidance or interpretation.