Last month, the CFPB fined JPMorgan Chase (JPMorgan) $4.6 million for various alleged violations of the FCRA. According to the consent order, the CFPB found that JPMorgan failed to have reasonable policies and procedures in place to ensure it provided accurate information to consumer reporting agencies, failed to inform consumers of the results of dispute investigations and failed to identify the consumer reporting agency on adverse action notices.

Policies and Procedures. The FCRA does not require financial institutions to provide information to consumer reporting agencies. However, if a financial institution elects to do so, the FCRA requires it to provide accurate information. Regulation V requires these financial institutions to have reasonable policies and procedures in place to ensure that information provided to consumer reporting agencies is accurate. The procedures should be designed based on the institution’s complexity and scope of activities and updated periodically. The rule also requires institutions to consider the interagency guidelines in developing their policies.

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