by. Henry Meier
It’s Football Season people! In addition to loving the game, the legal and compliance geek in me loves to see what the new points of emphasis will be for the referees this year. For example, a couple of years ago, they decided to really crack down on those great, open-field bone crushing tackleswith whichsafeties love to cripple wide receivers. This year, the NFL continues to reform itself having concluded after much medical research and recent legal threats that football is actually bad for your health and that blows to the head can actually damage someone.Now they are going to try to crack down on blows to the heads of running backs. Is flag football far off?
Now, I’m not trying to diminish the dangers posed by playing football but it is an intrinsically violent game and no matter how hard we try, it is going to stay that way. This brings me to a recent guidanceby the CFPB. One of the great points of emphasis of the Bureau since taking over as the nation’s consumer watch dog has been improving the accuracy of information in credit reports. It has even created quite a stir by suggesting that large numbers of Americans are being denied credit as a result of inaccuracies in credit reports maintained by the national credit reporting agencies.
In a 2012 report, theBureau was critical of the inability of the major reporting agencies to retain and forward all the documentation that a consumer has brought to their attention regarding an alleged inaccuracy. In yesterday’s guidance, the CFPBemphasized that it “expects furnishersto have reasonable systems and technology in place to receive and process notices of disputes and information regarding disputes, including information forwarded to them by CRAs.” Remember that if you report information to the credit bureau, you are a furnisher.
This dictate is a follow-up on the CFPB’sefforts to get the CRA’sto improve their technology so thatthey coul better retain consumer complaint information. I would hope that our good friends at the CRAswill be willing to provide a guidance to furnishersexplaining what technological baselines furnisherswill have to have in order to comply with the CFPB’s wishes. As someonewho hashad to read consumer complaints about alleged violationsin their creditreports,I have serious doubts thatwhat we need is the ability toread one more letterfrom an irate consumer with a perfectly good explanation as to why they haven’tpaid theirbills in the last three months. Remember that with orwithout this guidance, you’ll still have anobligation to researchdiscrepancies and correct errors where they exist.
