Brave New World for Data Furnishers

On September 4, 2013, the Consumer Financial Protection Bureau (“CFPB”) issued a Bulletin warning data furnishers that they face potential disciplinary action if they do not properly review information submitted to the credit bureaus in conjunction with consumer disputes of credit report information. Last week’s Bulletin appears to have been prompted by recent changes that the nationwide credit bureaus have made to their dispute handling procedures: information submitted by consumers with disputes is now imaged and communicated to the furnisher. Data furnishers, including banks, finance companies and debt collectors, might take this opportunity to review their data furnishing policies and procedures to ensure that they take into account the additional information being provided by credit bureaus with consumer disputes and meet CFPB's supervisory expectations.

CFPB Intends a Long-Term Focus on Credit Reporting -

The Fair Credit Reporting Act (“FCRA”) obligates companies that provide information about their transactions and experiences with consumers (“data furnishers”) to consumer reporting agencies (“CRAs”), including credit bureaus, to investigate disputes about that information. The obligation arises when the consumer disputes information directly with the data furnisher, or when a CRA advises the data furnisher that it has received a dispute from the consumer.

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Topics:  Banks, CFPB, Compliance, Creditors, Data Protection, Debt Collectors, FCRA, Nonbank Firms

Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates, Science, Computers & Technology Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »