TOPIC: FCRA

FCRA help!

Manager at a credit_union ($4.3BUSA)
Under FCRA, if the direct dispute involves a credit inquiry on a denied loan, are we even considered "furnishers"? I believe at one point there was a carve out to the rule that entities are not furnishers simply because they've had an inquiry of a report for a permissible purpose. Therefore can we be a furnisher for one applicants dispute, but not furnisher for another, dependent on the facts of the dispute? Thank you

    Credit Bureau Reporting for Those under Covid-19 Forbearance

    AVP at a bank ($190MUSA)
    How are servicer's handling credit bureau reporting for those mortgage customers who have accepted suspended payment arrangements under secondary market guidelines for COVID-19 borrower assistance?  Originally Fannie advised to suspend the credit reporting during the forbearance period and extend it into a repayment plan.  Now Fannie has retracted that instruction based upon FCRA guidance.  The notice to borrower from the FNMA servicing guide provides the wording option regarding credit bureau reporting suspension during periods impacted by natural disaster, which is how FNMA instructed servicer's to report the delinquency to them.  It would seem we would WANT to suspend reporting during this time.  When I inquired with Fannie Mae servicing, the response was that "it would just be assumed that the delinquency was due to Covid-19".  I have had customers decide to tough it out, rather than suspend payments, as they do not want to see their credit scores impacted.

      FCRA Direct Disputes

      Employee at a credit_union ($1.6BUSA)
      Ha anyone performed a compliance review on FCRA for Direct Credit Disputes?  Since it is a 2020 priority by the NCUA Examiners, I would like to have a review performed but not quite sure how to go about it.  If anyone has a testing spreadsheet to share, that would be appreciated.

        FCRA & Human Resources - Procedures for Denying Applicants Due to Credit/Background

        AVP at a bank ($3.7BUSA)
        Good morning, 
        Looking for any policies and procedures, training, or other resources that your institution uses that complies with the notification requirements under FCRA for taking adverse action on applicants for employment due to information in whole or in part of their credit report. Thanks in advance!

          Credit Score Disclosure Privacy for Consumer Loans

          Person at a bank ($3.7BUSA)
          For some of our consumer loans (non-RE secured), we use risk-based pricing, and use the risk-based pricing exception notices for these loans.  We are trying to determine a good control to ensure that the credit score disclosures are provided in a method that ensures privacy when there are multiple applicants.  For RE secured loans, we've centralized disclosures and send the notices separately in the mail, but many of the non-RE secured loans are closed day of application or next day, and the reg requires the notice "as soon as reasonably practicable after the credit score has been obtained, but in any event at or before consummation."  If we sent it in the mail, it certainly wouldn't be provided before consummation.

          Right now, we are just telling our frontline staff to provide separately, but the way our LOS prints out the documents (which we can't change), it would take some effort to separate them out.  It's hard/impossible to test if they are actually doing so, and there's no record to show we didn't just give them all to both borrowers.  

          Does anyone have better controls they use to ensure privacy in these situations they'd be willing to share?  Is our "We Told Them To" method enough?


            FCRA Credit Reporting Procedures

            VP at a bank ($466MUSA)
            We are going to charge off a loan but won't be repossessing the vehicle right away.  Is it okay to report the loan as a charge off and then change it to a repossession when the vehicle is actually repossessed?  Then we would change it back to a charge off once the vehicle is sold if there is a remaining balance?  Does anyone have detailed credit reporting procedures that covers charging off loans and credit bureau reporting?  The Credit Reporting Resource Guide covers what to report in each situation but doesn't cover actual procedures. 

              FCRA Model Disclosure Update Briefing

              Good Afternoon!

              Wondering how the recently issued interim final rule impacts you? The good news is the impact is not material. We attached a briefing for you on this issuance. If you use credit reports in conjunction with employment consideration, your HR Department will want to make sure they have the most recent version of the Summary of Consumer Rights. If you provide the second disclosure - rights in the event of ID theft - when any of your customers reports being a victim of identity theft (or provide this notice on your website), you'll want to make sure you have the updated version.

              Have an awesome afternoon!

                FCRA credit score exception notices

                Chief Compliance Officer at a bank ($114MUSA)

                Hi CBANC community -

                We recently went through an internal compliance exam and one of the FCRA findings was that the incorrect credit score exception notices were sent for loans secured by one to four units of residential real property. Are there any regulatory requirements that would require us to provide a correct exception notice to the borrower? Thanks in advance for your input!

                  Credit Reporting - Metric Report

                  Person at a credit_union ($1BUSA)

                  I am working the fatal error portion of our metric report. It looks like there are an inordinate amount of accounts on the report because the "date of account information" was updated on eOSCAR as the date the response was sent to the dispute, not the close date of the account. Has anyone run into this? Is there anyway to correct this other than submitting an AUD for each account?

                  Any advice on the fatal error report is greatly appreciated. This is somewhat new to me.