CFPB, Federal Agencies, State Agencies, and Attorneys General
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…
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…
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 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,…
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.”
The AGs have…
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 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. Under…
The CFPB has issued a special edition of its Supervisory Highlights that focuses on compliance with the FCRA and Regulation V. The report contains two main sections, with one devoted to supervisory observations at furnishers and the other devoted to supervisory observations at consumer reporting companies (CRCs). (The report was published in yesterday’s Federal Register…
Recently, the Consumer Data Industry Association (CDIA) and the Metro 2 Taskforce approved a new Special Comment Code in FAQ 69. According to CDIA’s press release , the new code, “DE = Debt Extinguished Under State Law,” applies—as the code suggests—to debts that have become extinguished under applicable law.
Under most state laws, the running…
Three more bills dealing with credit reporting were passed on Tuesday by the House Financial Services Committee. Like the four bills passed by the Committee last week, none of the bills passed yesterday received any Republican votes.
The bills, which are listed below, would make various amendments to the FCRA, including those described below:…
