Subscribers to each service will receive weekly emails and have the opportunity to discuss developments in each area during a monthly call.  Additionally, subscribers will be enrolled in an interactive, searchable, online database that enables subscribers to have 24-hour access to our information and analysis.

To further educate our current subscribers and anyone else interested

The CFPB has issued a report titled “Payment Amount Furnishing & Consumer Reporting” that highlights changes since 2012 in the furnishing of actual payment data to consumer reporting agencies.

The report indicates that:

  • Since 2012, the share of auto, student loan, and mortgage tradelines with actual payment data has generally trended upward.  The

For our financial services clients interested in monitoring important federal and state legal developments, Ballard Spahr has launched a comprehensive, national tracking service designed to serve the needs of specific segments of the consumer financial services industry.

Beginning January 2, 2021, Ballard is pleased to offer three new federal and state trackers, which are available

The CFPB announced that it has entered into a settlement with Afni, Inc. to address its alleged FCRA violations in furnishing consumer information to consumer reporting agencies (CRAs).  Afni is a debt collector specializing in the collection of debts on behalf of telecommunications companies.  The consent order imposes a $500,000 civil money penalty.

The FCRA/Regulation

Topics discussed include: CFPB plans to conduct a new study on credit reporting accuracy; FTC efforts to address unlawful practices by credit repair companies and abuse of identity theft reports; FTC focus on FCRA Red Flags Rule enforcement and how companies can avoid FTC scrutiny; considerations for companies in approaching CARES Act compliance through suppression

A Maine federal district court ruled that that two 2019 amendments to Maine’s credit reporting law are preempted by the federal Fair Credit Reporting Act and granted the motion for judgment filed by the plaintiff, the Consumer Data Industry Association (CDIA).

One of the amendments prohibited a consumer reporting agency (CRA) from reporting medical debt

We review the following findings and discuss their compliance implications: FCRA violations based on obtaining credit reports without a permissible purpose, incorrectly reporting the date of first delinquency, failing to conduct reasonable dispute investigations; Reg. E violations based on waivers of consumers’ dispute rights, use of incorrect date to determine timeliness of error notices, providing

The CFPB has released the Summer 2020 edition of its Supervisory Highlights.  The report discusses the Bureau’s examinations in the areas of consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending that were completed between September 2019 and December 2019.

Key findings are described below.

Consumer reporting.  CFPB examiners found:

The CFPB announced that it will hold its first Tech Sprint on October 5-9, 2020, with the participating teams to be focused on “developing a range of innovative approaches to electronically-delivered adverse action notices” and is seeking applicants to participate.

The Bureau indicated that in addition to conducting the Tech Sprint, it is considering

We are joined by Kelly Cochran, formerly with the CFPB and now Deputy Director of FinRegLab, a non-profit focused on the use of data and technology in financial services.  We examine credit reporting, credit scoring, and underwriting issues arising from the pandemic and CARES Act requirements, including the use of comment codes by furnishers and