On June 5, the CFPB revised its
Supervision and Examinations Manual to incorporate minor changes for larger participants under “Module 7 - Consumer Alerts, Identity Theft, and
Human Trafficking Provisions.” The updates specifically included FCRA and Regulation V requirements that prohibit credit reporting agencies (CRAs) from including information in consumer reporting in cases of human trafficking. Notably, the final rule regarding credit reporting on human trafficking victims was issued in 2022 (previously covered by InfoBytes here). The CFPB also stated that all CRAs must “establish and maintain written policies and procedures reasonably designed to ensure and monitor the compliance of the consumer reporting agency and its employees with the requirements of 12 CFR 1022.142.”
