Executive Summary
Maintaining compliance with the Fair Credit Reporting Act (FCRA) has always been challenging, and recent regulatory changes add to this complexity. This blog outlines essential updates for organizations navigating FCRA compliance, with a focus on recent CFPB priorities, expanding state-level scrutiny, and the pivotal role of accurate data in credit reporting.
Recent events at the CFPB have raised concerns about future enforcement. On April 18, 2025, the Trump administration announced plans to reduce the CFPB’s workforce by over 85%, from 1,500 employees to just 200.
Despite these cuts, an internal memo outlines the Bureau’s revised supervision and enforcement priorities for 2025, including FCRA compliance as a top priority, indicating that oversight efforts remain active on this bi-partisan issue. Additionally, the CFPB has asked a California judge to keep its lawsuit against Experian, alleging that the company unlawfully failed to investigate consumer disputes properly and included incorrect information in credit reports.
After a brief pause, clients have reported receiving notices of CFPB supervision activities related to FCRA issues. This suggests that while the CFPB may scale back on specific enforcement actions, it still prioritizes FCRA-related matters. After a temporary halt, the CFPB has also resumed publishing updates to its Complaint Database, with credit reporting-related complaints continuing to reach new highs.
Simultaneously, state regulators are becoming more proactive, striving to fill any enforcement gaps that they perceive may arise at the federal level.
In a recent data quality examination, we compared the results from our Data Quality Scanner with those from a regulator’s tool, and the findings were insightful. Our tool proved to be more detailed and beneficial for our clients in maintaining FCRA compliance. Additionally, we found that conducting independent Metro 2® data reviews using the Data Quality Scanner can reduce potential redress by up to 75%.
You can find more information in the Regulator Case Study.
These developments are a clear reminder that FCRA compliance must remain a top priority. Organizations must stay alert with rising private litigation and over one million CFPB complaints filed in Q1 alone (more than 80% related to credit reporting). Investing in automated FCRA data accuracy and compliance solutions, such as the Data Quality Scanner, significantly minimizes risks and reduces costly disputes and complaints.
CFPB Priorities
The CFPB has outlined its 2025 supervision and enforcement priorities in a memo from Chief Legal Officer Mark R. Paoletta. This reflects a significant strategic shift to reduce costs for businesses and consumers. Key points include:
- Reduced Supervisory Exams: The CFPB plans to cut supervisory exams by 50% to lower costs while focusing more on resolving consumer complaints.
- Enforcement Focus: The Bureau will prioritize cases that cause clear consumer harm. Key areas of concern include:
- Mortgage-related fraud
- Violations of the Fair Credit Reporting Act (FCRA)
- Issues under the Fair Debt Collection Practices Act (FDCPA)
- Improper fees
- Weak data security controls leading to consumer losses
- Direct Consumer Compensation: Instead of focusing on penalties that bolster the Bureau’s funds, the CFPB aims to return money directly to affected consumers.
- Support for Service Members: Service members, veterans, and their families will receive increased attention through targeted enforcement and remediation efforts.
- Reducing Duplicative Supervision: The CFPB will limit its participation in multi-state exams unless legally required, aiming to prevent overlaps in supervision with state agencies.
- Coordination with Federal Agencies: To minimize regulatory burdens, improved collaboration with other federal agencies is planned.
What This Means
According to Paoletta, the CFPB will concentrate on effectively resolving consumer complaints. This is particularly important for the credit reporting and scoring sector, where complaints have reached all-time highs, with the bulk of CFPB complaints (80%+) related to credit reporting. We recently covered this in our Q1 2025 Complaints update blog.
Maintaining the maximum possible data accuracy is essential, as recent statements from the CFPB’s chief legal officer indicate that high volumes of consumer reporting issues will attract regulatory attention.
State Enforcement of FCRA
Several U.S. states are enacting consumer reporting laws that extend beyond the federal Fair Credit Reporting Act (FCRA), reflecting a growing trend of state-level involvement in regulating credit reporting practices. These measures often focus on enhancing consumer protections related to the accuracy, timeliness, and permissible use of information in consumer reports.
A notable development is the increasing state action to address medical debt in credit reporting. For instance, California’s SB 1061, effective July 1, 2025, prohibits consumer credit reporting agencies from including medical debt in credit reports and bars creditors from using such debt in credit decisions. Similarly, Virginia’s HB 1370, effective July 1, 2024, prohibits certain health care providers and collection entities from reporting any portion of a medical debt to consumer reporting agencies.
These state-level initiatives contribute to a more complex regulatory landscape for furnishers and consumer reporting agencies operating nationwide. In the potential absence of uniform federal enforcement, organizations must navigate varying state requirements and interpretations, underscoring the importance of robust compliance systems to track and adhere to both federal and state regulations.
Staying Ahead of Changes
Ensuring the highest level of data accuracy is essential to mitigate growing FCRA-related risks. Our long-term analyses reveal that 15–25% of tradelines submitted without automated controls contain errors, highlighting the need for proactive oversight.
The Data Quality Scanner goes beyond what regulatory tools can detect, delivering a more thorough evaluation of your furnishing and dispute processes. By identifying and addressing issues before they escalate, it gives organizations the ability to prevent consumer harm and stay ahead of regulatory expectations.
Even with the potential for reduced federal enforcement, oversight remains active and future audits may review years of historical data. With rising complaint volumes, increased private litigation, and expanded state-level scrutiny, there’s never been a more important time to invest in automated data quality and compliance tools like the Data Quality Scanner.
We invite you to take our self-audit to see where your organization stands when it comes to credit reporting and FCRA compliance.
