The Consumer Financial Protection Bureau has once again put credit reporting square in its crosshairs, focusing exclusively on the practice in its latest Supervisory Highlights report. While the headline to the CFPB’s press release and the quote from Rohit Chopra mentioned the implications for victims of human trafficking, the report identifies deficiencies in how furnishers and the credit reporting companies are complying with the Fair Credit Reporting Act.
Why This Matters: The CFPB has long used the Supervisory Highlights report as the canary in the coal mine for its enforcement actions. If you want to know what issues the CFPB is most concerned with, the saying has gone, always check what it is writing about in this report, which references items noted during supervisory exams of regulated entities.
What It Found: Furnishers are violating the FCRA by failing to promptly correct and update information after determining that what it had been furnishing was inaccurate or incomplete. Some auto lenders, the CFPB noted, were furnishing incomplete or inaccurate information for years, such as incorrect dates of first delinquency.
Dispute Requirements: The CFPB also noted that examiners “are continuing to find” that furnishers are violating the FCRA by failing to notify the credit bureaus that the accuracy or completeness of items being furnished are subject to dispute.
Reasonable Investigations: Debt collection furnishers continue to just delete tradelines after receiving a direct dispute instead of conducting an investigation, the CFPB noted.
- “As the Bureau has previously explained, simply deleting tradelines in response to a direct dispute does not satisfy furnishers’ responsibility to conduct a reasonable investigation with respect to the disputed information.”
