CFPB Report Details Problems, New Requirements Consumer Reporting Companies Must Implement

Some of the problems that the CFPB documented in its report include:

  • • No programs to test the accuracy of credit reports that the CRCs produced, prompting Director Cordray to remark “we were surprised to find that [the CRCs’] quality control systems were either rudimentary or virtually non-existent.”
  • •Deficiencies regarding the CRCs’ relationship with furnishers and information sources such as:
    • • Insufficient monitoring and re-vetting of furnishers to ensure they were continuing to meet their legal and other obligations
    • • No policies to monitor dispute data regarding furnishers
    • • Lack of oversight of public records vendors
    • • Furnishers were rarely provided with feedback regarding data quality, and were sometimes charged fees for data-quality reports
  • • Deficiencies regarding the dispute process, leading Director Cordray to call the system “badly broken,” such as:
    • • Failure to review and consider all relevant information submitted by consumers when conducting dispute reinvestigations
    • • Failure to consistently notify furnishers of disputes, as well to inform them of modifications and deletions resulting from disputes
    • • Failure to properly describe the results of dispute investigations in notices to consumers