Federal Agency Interpretation

This is CFPB Bulletin 2012-09 (Nov. 29, 2012) concerning the FCRA and Reg.

This is CFPB Compliance Bulletin 2016-01 (Feb. 3, 2016) concerning the FCRA requirement that furnishers establish and implement reasonable written policies and procedures regarding the accuracy and integrity of information furnished to all CRAs, including specialty CRAs, such as the furnishing of deposit account information to CRAs.

This is CFPB Bulletin 2012-09 (Nov 29, 2012) concerning the FCRA’s “streamlined process” requirement for consumers to obtain free annual reports from nationwide specialty consumer reporting agencies (NSCRAs), as required by the FCRA and Reg.

This CFPB Bulletin 2013-09 (Sept. 4, 2013) concerns the FCRA’s requirement that furnishers investigate disputes and review “all relevant” information provided by CRAs about the dispute. The CFPB expects furnishers to have reasonable systems and technology in place to receive and process notices of disputes and information regarding disputes, including relevant documentation, forwarded to them by CRAs.

This CFPB Bulletin 2014-01 (Feb. 27, 2014) concerns the FCRA’s requirement that furnishers conduct investigations of disputed information.  The CFPB is concerned that a furnisher may respond to a consumer’s dispute, without conducting an investigation, simply direct the CRA to delete the item it has furnished.