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    How the TransUnion v. Ramirez decision and the CFPB are impacting FCRA Legal and Compliance Activity [CC]

    How the TransUnion v. Ramirez decision and the CFPB are impacting FCRA Legal and Compliance Activity [CC]
    CLE 60 min

    How the TransUnion v. Ramirez decision and the CFPB are impacting FCRA Legal and Compliance Activity [CC]

    Join our panel for a high-level overview of the Fair Credit Reporting Act (���FCRA���) and furnishing ��� how consumer information is collected, used, and disputed by consumers, data furnishers and consumer reporting agencies (CRAs) roles and responsibilities, including discussing the Metro 2�� format.

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    Closed Captioned.

    Listen to a review of disputes including differences between disputes and complaints, and the requirement to conduct a reasonable investigation, including of direct disputes to the furnisher, and reasons for why an investigation would not be required at all), indirect disputes sent to the CRA and forwarded to the furnisher (requiring an investigation within 45 days or the dispute will be deleted by the CRA), and common regulatory and operational issues with disputes, such as the adequacy of policies and procedures, reasonableness/timeliness of investigations, deleting/modifying tradelines, volume of disputes, lag time of dispute reporting, CRAs rejection of furnishing updates, and variability in how CRAs report and ingest credit data.

    Our distinguished faculty highlight and explain the recent uptick in CFPB complaints since COVID-19 (from 2019 to 2020), and the how and why the majority of all CFPB complaints relate to credit reporting, with many complaints relating to inaccurate information on a consumer���s credit report.

    The Supreme Court���s decision in TransUnion v. Ramirez is used as a case study, demonstrating how plaintiffs in a class action need to show concrete harm (as opposed to alleged reputational harm). The panel also explains the importance for furnishers to reduce instances of harm to consumers per the TransUnion v. Ramirez case as this may reduce exposure to potential litigation.

    This program outlines a few key considerations and best practices:

    1. Maintaining appropriate documentation including policies and procedures aligned with FCRA and current processes

    Conducting reasonable investigations of disputes
    Documenting all furnishing business rules including any deviations from the Metro 2�� guide
    2. Furnishing Quality Control and testing on at least a monthly basis

    Performing data analytics on the full furnishing file
    Sample testing of tradelines
    3. Conducting dispute investigations with complaint tracking and analysis

    Tracking both direct and indirect volumes by dispute/complaint type and aging of disputes and complaints
    Identifying systemic issues with credit reporting processes if there are upticks in certain dispute and complaint types
    4. Change management

    Staying abreast of regulatory changes such as the CARES Act requirements
    Staying ahead of product and system changes and engage early and often with business, technology, and other stakeholders to understand the downstream impact to credit reporting

    Product Details

    Moderators

    David King

    Sponsors

    ABACLE, FTI Consulting

    Product Code

    CE2110FTIOLC

    Duration

    60

    Publication Date

    10/11/2021 12:00:00 AM

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