Federal Agency Interpretation

In response to recent inquiries, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issues this bulletin to provide guidance about compliance with the fair lending requirements of the Equal Credit Opportunity Act (“ECOA”), and its implementing regulation, Regulation B. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act” or “Act”) granted CFPB authority to supervise and enforce compliance with the ECOA for entities within CFPB’s jurisdiction and to issue regulations and guidance to interpret the ECOA.

Credit card issuers market various “add-on” products to card users, including debt protection, identity theft protection, credit score tracking, and other products that are supplementary to the credit provided by the card itself. This bulletin outlines the Consumer Financial Protection Bureau’s (“CFPB” or “the Bureau”) expectation that institutions under its supervision and their service providers offer such products in compliance with Federal consumer financial law.

The Consumer Financial Protection Bureau (CFPB or the Bureau) expects to issue a proposal next month to refine three elements of its rule regarding foreign remittance transfers. The proposal will be narrowly targeted to address the rule’s provisions on: (1) errors resulting from incorrect account numbers provided by senders of remittance transfers; (2) the disclosure of certain foreign taxes and third-party fees; and (3) the disclosure of sub-national, foreign taxes. The Bureau will proceed on a fast track with a notice of proposed rulemaking, which will propose these changes.

The Fair Credit Reporting Act (FCRA) requires nationwide specialty consumer reporting agencies (NSCRAs) to provide, upon request of a consumer, a free annual disclosure of the consumer’s file, commonly known as a consumer report. The FCRA’s implementing Regulation (Regulation V) includes a rule mandated by the FCRA that requires each NSCRA to establish a “streamlined process for consumers to request [their free annual] consumer reports . . . which shall include, at a minimum, the establishment by each such agency of a toll-free telephone number for such requests.” 15 U.S.C.

This bulletin provides guidance about compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B, for indirect auto lenders that permit dealers to increase consumer interest rates and that compensate dealers with a share of the increased interest revenues. This guidance applies to all indirect auto lenders within the jurisdiction of the Consumer Financial Protection Bureau (CFPB), including both depository institutions and nonbank institutions.

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), all covered persons or service providers are legally required to refrain from committing unfair, deceptive, or abusive acts or practices (collectively, UDAAPs) in violation of the Act. The Consumer Financial Protection Bureau (CFPB or Bureau) is issuing this bulletin to clarify the contours of that obligation in the context of collecting consumer debts.

The Fair Credit Reporting Act (FCRA) generally requires a consumer reporting agency (CRA) to notify a furnisher when a consumer disputes the accuracy or completeness of an item of information provided by the furnisher to the CRA. The CRA must also promptly provide the furnisher “all relevant information” regarding the dispute that the CRA timely received from the consumer. The furnisher, in turn, must “conduct an investigation with respect to the disputed information,” “review all relevant information” provided by the CRA, and respond appropriately based on the result of the investigation.

Debt buyers, debt collectors, and others who furnish information to credit reporting agencies have a variety of obligations under the Fair Credit Reporting Act (FCRA) and Regulation V. The Consumer Financial Protection Bureau (CFPB) issues this bulletin to highlight one of those obligations – the obligation of furnishers to investigate disputed information in a consumer report. The CFPB is concerned that, when a furnisher responds to a consumer’s dispute, it may, without conducting an investigation, simply direct the consumer reporting agency (CRA) to delete the item it has furnished.

The Consumer Financial Protection Bureau (CFPB or Bureau) is issuing this Bulletin to inform credit card issuers of the risk of engaging in deceptive and/or abusive acts and practices1 in connection with solicitations that offer a promotional annual percentage rate (APR) on a particular transaction over a defined period of time. These transactions include, but are not limited to, convenience checks, deferred interest/promotional interest rate purchases, and balance transfers.

The Consumer Financial Protection Bureau (Bureau) issues this compliance bulletin to remind creditors of their obligations under the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B, to provide non-discriminatory access to credit for mortgage applicants using income from the Section 8 Housing Choice Voucher (HCV) Homeownership Program.