The CFPB, in its recently released supervisory highlights, detailed issues with consumer report information related to accuracy and dispute handling. In a new NAFCU Compliance Blog post, NAFCU Regulatory Compliance Counsel Loran Jackson reviews the requirements credit unions are subject to under the Fair Credit Reporting Act (FCRA) when furnishing consumer report information.
Under the FCRA, credit unions have a responsibility to accurately furnish consumer report information. If a member disputes their report, the credit union must fulfill FCRA requirements for an investigation. Jackson flags that the bureau’s report found some furnishers were not completing dispute investigations in the required amount of time, while others weren’t completing an investigation at all.
“The CFPB also found that some institutions completed the investigation, determined information in the consumer report was inaccurate, and then failed to furnish corrected information or notify the consumer reporting companies that the information was inaccurate,” Jackson writes. “More specifically, some furnishers failed to update information about accounts that were paid in full or settled, and continued to report inaccurate information to consumer reporting companies for months after the information was disputed.”
Jackson outlines the dispute process, which includes:
- conducting an investigation with respect to the disputed information, generally within 30 days;
- reviewing all relevant information provided by the consumer reporting company;
- reporting the results of the investigation to the consumer reporting company; and
- reporting inaccurate or incomplete information to all consumer reporting companies to which the information was furnished.
In addition, Jackson reminds credit unions to keep written policies for furnishing accurate information and procedures for investigating disputes. More details are available in Jackson’s full Compliance Blog post.
NAFCU’s Compliance Team publishes a new blog every Monday, Wednesday, and Friday on key regulatory issues affecting credit unions. Sign up to receive new Compliance Blog posts.
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