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2016 CFBP Bulletins

CFPB Bulletin 2016-01
February 2016

FCRA’s Requirement that Furnishers have Written Policies and Procedures regarding the Accuracy and Integrity of Information Provided to All Consumer Reporting Agencies

The CFPB issued Bulletin 2016-01 to remind furnishers1 of their obligations, under Regulation V, to establish written policies and procedures regarding the accuracy and integrity of consumer information they provide to credit reporting agencies (CRAs) including information provided to “specialty CRAs” such as those that accept deposit account history and information.  The bulletin notes that “the establishment and implementation of reasonable policies and procedures are essential components of a fair and accurate credit reporting system.”  The bulletin can be found here.

  • According to the CFPB, such policies and procedures help protect against the provision of inaccurate information that could lead to adverse consequences for consumers such as being denied a loan at a more favorable interest rate or being denied a checking account.
  • Furnishers are required to establish and implement reasonable written policies and procedures regarding the accuracy and integrity of consumer information provided to CRAs.
  • When developing policies and procedures, furnishers must take into consideration the factors listed in the “Interagency Guidelines Concerning the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies” found in Appendix E to Regulation V 2.

1: “Furnisher” means an entity that furnishes information relating to consumers to one or more consumer reporting agencies for inclusion in a consumer report.  An entity is not a furnisher when it: (i) provides information to a consumer reporting agency solely to obtain a consumer report in accordance with sections 604(a) and (f) of the FCRA; (ii) is acting as a “consumer reporting agency” as defined in section in section 603(f) of the FCRA; (iii) is a consumer to whom the furnished information pertains; or (iv) is a neighbor, friend, or associate of the consumer, or another individual with whom the consumer is acquainted or who may have knowledge about the consumer, and who provides information about the consumer’s character, general reputation, personal characteristics, or mode of living in response to a specific request from a consumer reporting agency.

2: 12 CFR Part 1022, Appendix E.