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We look at the practices found to be unlawful by CFPB examiners in these markets, discuss what the findings signal for future scrutiny of these markets by the “new CFPB”, and share practical takeaways for companies operating in these markets.  Issues highlighted in our conversation include the CFPB’s findings regarding “unreliable furnishers,” furnisher handling of “frivolous or irrelevant” disputes, interest accrual on debts in collection, and mortgage servicer consideration of private mortgage insurance termination dates when estimating disbursements in an annual escrow analysis.… Continue Reading

On May 26, 2021, the House Financial Services Committee’s Subcommittee on Oversight and Investigations will hold a hearing, “Consumer Credit Reporting: Assessing Accuracy and Compliance.” The witnesses include representatives from the “big three” consumer reporting agencies and the National Consumer Law Center.  Based on the Committee memorandum, lawmakers are likely to focus on consumer report accuracy and the dispute resolution process.… Continue Reading

On May 6, 2021, the CFPB’s Office of Servicemember Affairs issued its eighth annual report summarizing its activities from January 1 through December 31, 2020.  The report discussed the Office’s consumer outreach and educational efforts, servicemember complaint trends, and priorities for 2021.

The Office’s educational outreach focused on specific economic challenges and resources related to the COVID-19 pandemic, including forbearance programs and emergency grants.… Continue Reading

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 in subscribing to the trackers about how to maximize the online database, we will be offering preview sessions to provide training on the various tools available through the dashboard, such as the interactive map and the search functions that will allow information to be sorted by topic, jurisdiction, date, and for the FCRA tracker, by federal court and counsel for plaintiffs.… Continue Reading

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 as a package or individually, depending on your financial institution’s needs:

  • Collections Tracker – providing expanded coverage of relevant federal and state legislative and regulatory developments impacting consumer collection activities; this will still include our current COVID-19-related coverage, but the tracker will be expanded to include new and evolving federal and state collection legislative and regulatory initiatives.
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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 the treatment of forbearance-related information by creditors, and that are likely to arise in the transition from short-term forbearances to long-term arrangements. … Continue Reading

The CFPB issued ten FAQs for industry that address the CARES Act’s credit reporting requirements and other COVID-19-related credit reporting issues.

Several of the FAQs discuss the Bureau’s Policy Statement issued in April 2020 concerning COVID-19 considerations relevant to how the Bureau will exercise its supervisory and enforcement authority regarding FCRA and Regulation V compliance, especially in light of the CARES Act. … Continue Reading

A group of attorneys general (AGs) from twenty-one states, the District of Columbia, and Puerto Rico has sent a letter to CFPB Director Kraninger requesting that the CFPB immediately withdraw its guidance regarding credit reporting during the COVID-19 pandemic and “resum[e] vigorous oversight of consumer reporting agencies and enforcement of the FCRA.”… Continue Reading

The CFPB has issued a policy statement concerning COVID-19 considerations that will be relevant to how the CFPB chooses to exercise its supervisory and enforcement authority regarding compliance with the Fair Credit Reporting Act and Regulation V, especially in light of the CARES Act.

The CFPB states that it “understands that the current crisis impacts the financial well-being of consumers and poses operational challenges for consumer reporting agencies and furnishers, including staffing challenges, that could temporarily impede their ability to timely comply with their statutory and regulatory consumer reporting obligations.” … Continue Reading

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) includes the following provisions of particular interest to members of the consumer financial services industry:

Credit Reporting.  Section 4021 (Credit Protection During COVID-2019) amends the Fair Credit Reporting Act to impose new COVID-19 related reporting requirements on furnishers of information to consumer reporting agencies. … Continue Reading