Benchmark: See Where You Stand

Compare the accuracy of your credit reporting data to your peers with our 1-Minute Self-Audit covering key credit reporting and FCRA accuracy and compliance processes.

With the threat of costly disputes, complaints, lawsuits, and regulatory inquiries looming, it’s important to ensure your credit reporting accuracy and compliance processes are in line with your peers. But it can be hard knowing where to start. That’s where the Data Quality Scanner (DQS) can help.

CDIA Consumer Data Connect Conference Insights and Takeaways

Last week we had the privilege of attending the CDIA’s Consumer Data Connect Conference in Washington, DC. This event stands as the singular stage for legal experts, influential thought leaders, regulators, and officials to connect over every facet of the consumer reporting ecosystem.

Our CEO and Head of Product were able to attend this event and shared some of their key takeaways below!

Preparing for CFPB Exams

In an on-stage discussion regarding preparation for CFPB exams, the Deputy Assistant Director of the CFPB, Erin Jeweler, said that the agency is looking at Metro 2® data and ensuring that furnishers do as well.

This is consistent with what Bridgeforce Data Solutions has been hearing across the industry, that the CFPB has been requesting Metro 2® data files for significant history and doing analyses of the data. While hearing this anecdotally, this is the first time that we have heard it directly from the CFPB.

During this same presentation, Chris Willis, Partner and Co-Leader of the Consumer Financial Services Regulatory Practice Group at Troutman Pepper, shared a slide saying that furnishers should expect the CFPB to ask for Metro 2® files, ACDV data, and AUD’s during these exams. He also mentioned that it is important to identify ‘meritorious disputes’ and figure out their root causes.

Another point that Willis made was that he sometimes hears furnishers express concerns about creating a ‘list of issues’ out of fear that having a list would hurt them in an exam. He mentioned that it is better to have such a list and credible plans for addressing the issues than to not have a list, since not having one invites the CFPB to create it for you. This received approving nods from Jeweler as well.

Updates to the Metro 2® Consumer Reporting Resource Guide

At the conference the Metro 2® Task Force announced that the updated Consumer Reporting Resource Guide (CRRG) will be released on May 16.

With these new updates being released, the Data Quality Scanner will have these updates reflected within 90 days (August 14).

Expected CFPB Rulemaking

Another key point of discussion at the conference was regarding the expected rulemaking coming from the CFPB. These potential rules may impact the classification and therefore potential uses of credit header data, with many examples of potential negative consequences of a rules change if it prohibits any current legitimate uses.

Find Out Where You Stand, Now

→ Take the Self-audit

If you don’t have an automated solution that comprehensively assesses all of your accounts, like DQS, you don’t really know where you stand. For initial baseline results, we see clients have between 15-25% of accounts with at least one discrepancy. Complete the self-audit now.

Check box if you meet the requirement

Q1

Does your organization have a formal process to conduct reviews prior to transmission of credit reporting files to the CRAs?

Q2

Does your organization have a formal process to review the reject & error reports from the CRAs every month and other applicable internal reports to ensure any corrections required are made promptly?

Q3

Do you have any automated tools or solutions to review furnishing data across your enterprise and drill down to both the rule and account level to ensure compliance with credit reporting (e.g., Metro 2®) reporting requirements?

Q4

If yes, do your automated tools or solutions compare month-over-month credit reporting data to see where values do not conform to reporting requirements, and where fields contain illogical progressions?

Q5

Do you formally conduct root-cause analysis of these credit reporting corrections to examine if the identified issue(s) are impacting a larger number of customers?

Q6

Are you including credit reporting as part of regression testing when you make changes to the systems that produce your credit reporting furnishing files?

Q7

Have you examined upstream operational processes that can affect credit reporting furnishing accuracy (e.g., id theft, bankruptcy, repossession, forbearance, charge-off)?

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