Fair Credit Reporting Act Compliance – Ten Critical Issues
According to a study conducted by the Federal Trade Commission (FTC), 26% of credit reports examined included at least one “potentially material” error in one or more of the three credit reports from Experian, TransUnion or Equifax.
Some of these errors can negatively affect a consumer’s credit score by up to 100 points.
The Fair Credit Reporting Act has been in effect since 1971, but has been amended substantially over the years, most recently by significant changes in the FACT Act. Even though this regulation is an “oldie but goodie”, there are still many issues and violations have been cited.
The CFPB tracks complaints, and the “credit reporting” complaint category has increased focus by all the regulators. In addition, increased identify theft, fraud, and cyber crime have a direct relationship to the potential for inaccurate credit reports. There are numerous compliance challenges, ranging from what you can tell one joint applicant about the other applicant’s credit, to when the FCRA portion should NOT be included with the adverse action form.
What should your bank or credit union be doing to reduce the compliance risk of complaints and FCRA violations? Join us for a discussion of 10 issues that should be addressed in an effective FCRA compliance program.
- What are the key definitions in the Fair Credit Reporting Act for “person”, “consumer” “consumer report” and “consumer reporting agency”?
- What are the permissible purposes for a consumer reporting agency to furnish a consumer report?
- What requirements must be followed by the USERS of consumer reports? There is increased emphasis on evaluation of “consumer harm” by regulators. Is your financial institution responding appropriately to direct disputes from consumers? What about the response to disputes and e-Oscar* inquiries from the national credit reporting agencies? (* stands for Online Solution for Complete and Accurate Reporting)
- What are the responsibilities to “furnish” accurate information?
- Is there a restriction on sharing credit and debit card numbers on electronic receipts?
- How should “negative” credit performance information be provided?
- How should adverse action/FCRA notices be given?
- Credit score disclosure notices – what’s required?
- Use of medical information – what are the rules?
- Exam procedures for FCRA – highlights and best practices.
Customer service representatives, branch managers, lenders, loan operations, credit administration, compliance personnel, collectors, and anyone who pulls credit reports, processes loan applications, or responds to questions about credit reports in the lending process
Susan Costonis is a compliance consultant and trainer. She frequently provides consulting services to financial institutions regarding fair lending and other compliance management issues. Her 37 year career in banking and training began with 20 years at First National Bank, an affiliate of Wells Fargo Bank, in Fort Collins, CO. Susan has been a bank compliance consultant or compliance officer in Louisiana since 1998.
During her career, Susan has successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve. She is a Certified Regulatory Compliance Manager and completed the ABA Graduate Compliance School and the Graduate Banking School of the University of Colorado. Susan regularly presents seminars to financial associations.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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