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CFPB Provides Dispute Guidance to FCRA Furnishers on Enhanced e-OSCAR

Changes to the systems by which banks and other entities (also known as “furnishers”)  supply credit reporting agencies with consumer credit information prompted a Bulletin yesterday from the Consumer Financial Protection Bureau emphasizing the greater role it sees documents playing in the consumer credit dispute process.

In announcing its expectation that furnishers review “all relevant information” when responding to consumer disputes, the CFPB reiterates what is already required by FCRA’s section 1681s-2(b). When responding to a consumer’s dispute concerning information furnished by it to a credit reporting agency, a furnisher is required, among other things, to “review all relevant information provided by the CRA . . .”

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But the Bulletin emphasizes that “all relevant information” should now be construed to include “documents that the CRA includes with the notice of dispute or transmits during the investigation.” The emphasis on documents reflects changes in the e-OSCAR system used by furnishers and CRAs to exchange information. The e-OSCAR system recently received the capability to transmit documents to furnishers as part of a consumer’s dispute.  Furnishers, according to the Bulletin, must have systems capable of receiving these documents and consider them as part of their dispute processes.

The Bulletin advises that compliance with the requirement to review “all relevant information” can be demonstrated through, among other things:

1) maintaining a system reasonably capable of receiving dispute information from CRAs, including documents;

2) conducting an investigation of the dispute, which includes review of “all relevant information” provided by the CRA as well as information from a furnisher’s own files 1

Furnishers should anticipate CFPB scrutiny of their dispute processes in light of the Bulletin and undertake appropriate measures, if necessary, to make their systems compliant.

Consumer advocacy organization Public Justice interprets the Bulletin to essentially require a person to “review the documents and [] make a judgment about whether the entry is erroneous.”

A copy of the Bulletin is available here. The CFPB press release concerning the Bulletin can be obtained at this link.

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  1. In addition, the Bulletin calls for reporting the results of the investigation to the CRA that provided the dispute; if the information was corrected, then provide every CRA that had received the original information with the corrected information; and, for information that is incomplete, inaccurate or cannot be verified, modifying, deleting or permanently blocking such information from being furnished

Donald Maurice provides counsel to the financial services industry, successfully litigating matters in the state and federal courts in individual and class actions. He has successfully argued before the Third, Fourth and Eighth Circuit U.S. Courts of Appeals, and has represented the financial services industry before several courts including as counsel for amicus curiae before the United States Supreme Court. He counsels clients in regulatory actions before the CFPB, and other federal and state regulators and in the development and testing of debt collection compliance systems. Don is peer-rated AV by Martindale-Hubbell, the worldwide guide to lawyers. In addition to being a frequent speaker and author on consumer financial services law, he serves as outside counsel to RMA International, on the governing Board of Regents of the American College of Consumer Financial Services Lawyers and on the Governing Committee of the Conference on Consumer Finance Law. From 2014 to 2017, he chaired the ABA's Bankruptcy and Debt Collection Subcommittee.

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