In its latest edition of Supervisory Highlights, the CFPB indicated it’s seeing creditors pulling credit without a permissible purpose to do so. The Fair Credit Reporting Act (FCRA) does not require consumers to consent prior to pulling credit (unless if for employment purposes), if you otherwise have a permissible purpose to do so. For example, credit reports can be obtained …in connection with a credit transaction involving the consumer on whom the information is to be furnished and involving the extension of credit to, or review or collection of an account of, the consumer…
It’s also important to point out, that any contract you have with a consumer reporting agency likely requires you to …certify the purposes for which the information is sought, and certify that the information will be used for no other purpose. While there are a variety of regulatory risks involved with reusing credit reports, you could be in violation of your contract if you reuse a previously obtained credit report, as well.
In addition to pulling credit without a permissible purpose, the CFPB indicated it’s also seeing issues in the handling of disputes and inaccurate reporting. It’s clear the FCRA remains a focus of the CFPB, as evidenced by the Fall 2019 Supervisory Highlights, a special edition on Consumer Reporting.
For more details on issues identified within the summer edition of The CFPB’s Supervisory Highlights, check out our October edition of Banking on BCC.
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Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager.
Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelor’s Degree in Business Administration, and is a graduate of the ABA Compliance School.
Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!