The CFPB Published its Spring 2024 Supervisory Highlights this week. The report covers findings from examinations in connection with credit reporting companies (CRC) and furnishers that were completed from April 1, 2023, through December 31, 2023.
Here are a few key highlights
1. Inaccuracy in the credit reporting system is a long-standing issue that remains a problem today. Accordingly, the CFPB continues to prioritize examinations of consumer reporting companies (CRC) and furnishers.
2. In recent reviews of CRC, examiners found that CRC’ accuracy procedures:
- Failed to comply with the duty to follow reasonable procedures to assure maximum possible accuracy because the CRC failed to adequately monitor dispute metrics that would suggest a furnisher may no longer be a source of reliable, verifiable information about consumers
- Continued to include information in consumer reports that were provided by unreliable furnishers without implementing procedures to assess the accuracy of information provided by unreliable furnishers
- Did not monitor metrics and thresholds tied to objective measures of inaccuracy or unreliability.
In response to these findings, CRC were directed to revise their accuracy procedures to identify and monitor furnishers and take corrective action regarding data from furnishers whose dispute response behavior indicates the furnisher is not a source of reliable, verifiable information about consumers.
3. In recent reviews of furnishers, examiners found deficiencies in furnishers’ compliance with FCRA and Regulation V accuracy, dispute investigation and identity theft requirements because the furnishers:
- Are violating the FCRA duty to promptly correct and update furnished information after determining that such information is incomplete or inaccurate
- Continue to report dates of first delinquency inaccurately for several months after determining that they were reporting inaccurately due to various system coding issues
- Failing to update the dates of first delinquency for the accounts in bankruptcy when they determined the accounts were in bankruptcy
In response to these findings, furnishers were directed to update their internal controls related to promptly correcting or updating furnished information after determining it is incomplete or inaccurate, and engaging in lookbacks to remediate the furnishing of the previously impacted accounts.
We will continue to closely monitor and report on CFPB and other Regulator publications and actions related to credit bureau reporting and disputes as they become available. In the interim, we invite you to review our Low-Cost|Low-IT Data Quality Scanner Solutions that can help CRC and Furnishers quickly and easily avoid these issues before they become costly regulatory actions or lawsuits.
