CFPB Warns Data Furnishers on Reasonableness of Written Policies and Procedures: First Compliance Bulletin of the Year

3 min

In its first compliance bulletin of 2016, the CFPB once again focuses on consumer information furnishing practices of financial institutions. The bulletin focuses on the Fair Credit Reporting Act's requirement that furnishers establish and implement reasonable written policies and procedures regarding the accuracy and integrity of information furnished to all consumer reporting agencies (CRAs). The Bureau reminds furnishers of their obligation under Regulation V to employ such policies and procedures, but also warns furnishers that these requirements equally apply when reporting to specialty CRAs. According to the CFPB, the failure of a furnisher's policies and procedures to account for furnishing to all types of CRAs would render such policies and procedures inadequate under the law.


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