Hello, compliance compadres! As you are well aware, the Fair Credit Reporting Act (FCRA) and its requirements govern the furnishing of information to the credit reporting agencies (“CRAs”). The FCRA subjects data furnishers to various duties, such as, but not limited to the following: the duty to provide accurate information; the duty to provide notice of dispute; the duty to provide notice of delinquency of accounts and the duty to provide notice of negative information to members. See, 15 U.S.C. § 1681s-2(a).

Recently, I have spoken to a few members about pending changes at the big three credit reporting agencies (Transunion, Equifax, and Experian) that are aimed at improving the accuracy of consumer credit reports and better enabling consumers to dispute and correct incorrect credit information. The changes are a result of increased regulatory supervision and a 2015 consumer protection settlement with state attorneys general. Today, I will provide you with some insight into the regulatory and litigation background that and what that may mean for credit unions.

Background

The CFPB has reported that consumers continue to complain about the credit reporting industry in high numbers. The Bureau reports handling approximately 185,700 credit reporting complaints as of February 1, 2017.

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