CFPB Warning and Bulletin for Nationwide Specialty CRAs

The Consumer Financial Protection Bureau (“CFPB”) has sent warning letters to several nationwide specialty consumer reporting agencies (“CRAs”), notifying the CRAs that the CFPB believes that the CRAs are not complying with the Fair Credit Reporting Act (“FCRA”) provisions designed to ensure easy consumer access to free annual credit reports and requiring a response within 30 days. The CFPB also has issued a Bulletin on the same topic. The warning letters and Bulletin underscore the importance that the CFPB is placing on the FCRA’s free credit report provisions.

The FCRA requires nationwide specialty CRAs to provide free annual credit reports to consumers, and to establish a “streamlined process” to facilitate consumer access to those reports. (Nationwide specialty CRAs are defined by the FCRA to include those CRAs that maintain files relating to medical records or payments, tenant history, check writing history, employment history and insurance claim history.) This streamlined process must include a toll-free telephone number, which must be posted on the CRA’s Web site and listed in the telephone directory. CRAs also must implement “reasonable procedures” to anticipate, and respond to, the volume of consumers who will use the streamlined process and must provide consumers with clear instructions on how to request reports.

Please see full alert below for more information.

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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.

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