Archive

FCRA REVISIONS UNDER WAY

On August 24, 2020 the Federal Trade Commission (FTC) issued a Notice of Proposed Rulemaking (NPRM) that would update several rules contained in the Fair Credit Reporting Act (FCRA) with provisions contained in the Dodd-Frank Act. It is important to consider that rules under the FCRA that impact auto dealers are issued by the FTC. FCRA rules that impact financial institutions are issued by the Consumer Financial Protection Bureau. The FTC issued five separate NPRMs […]

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CARES ACT IMPACT ON CREDIT REPORTING

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) became law on March 27, 2020. On April 1, 2020 the Consumer Financial Protection Bureau (CFPB issued a statement of policy on Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act. The statement highlights furnishers’ responsibilities under the CARES Act and inform consumer reporting agencies and furnishers of the CFPB’s flexible supervisory and enforcement approach […]

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EGRRCPA PROTECTIONS FOR SERVICEMEMBERS

One year ago, the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) established several new protections for servicemembers and veterans, including: Holding lenders to more stringent requirements when they participate in VA’s refinance programs Ensuring continued foreclosure protections for servicemembers up to one year after they leave active duty Prohibiting medical debt that should have been paid by the VA to be reported as  part of a veteran’s credit history Providing free credit monitoring […]

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GUIDANCE ON VOLUNTARY PRIVATE EDUCATION LOAN REHABILITATION PROGRAMS

On February 4, 2019 the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution letter (FIL-5-2019) dealing with voluntary private education loon rehabilitation programs. The notice was issued jointly with the Board of Governors of the Federal Reserve System (Fed). The FIL is designed to make financial institutions aware of an amendment to section 623 of the Fair Credit Reporting Act (FCRA). This amendment is contained in section 602 of the Economic, Growth, Regulatory Relief […]

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WORKS IN PROCESS

“For the rest of this year and the next, our rulemaking agenda at the Consumer Bureau will remain quite active.” Director Richard Cordray recently stated. So what can we expect to see from the CFPB? The agency is working on new or revised rules for: Overdraft fees, including the opt-in process for overdraft coverage of electronic transactions; Collection and publication of data on small business lending (The Dodd-Frank Act required final rules by July 21, […]

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