CFPB Issues Opinion On “Clearly False” Consumer Report Data

Lori Kalani, Bernard Nash
Cozen O'Connor
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Cozen O'Connor

  • The CFPB issued an Advisory Opinion and accompanying press release clarifying the agency’s position that the Fair Credit Reporting Act requires consumer reporting agencies to implement reasonable internal controls to prevent the inclusion of clearly false data in consumer reports, particularly logically inconsistent or impossible information.
  • Specifically, the Advisory Opinion explains that consumer reporting agencies are uniquely positioned to identify obvious inaccuracies and implement policies and procedures to eliminate them. Examples include conflicting or inconsistent information, such as an account with a status of paid in full but that still reflects a balance due, or an original loan amount that increases over time, which is logically impossible.
  • The Advisory Opinion also examined other examples of clearly false data—such as a Date of First Delinquency more recent than the start of a delinquency—and emphasized the heightened risk of incorrect information to minors, particularly those in the foster care system.

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