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ARTICLE · 07 SEPTEMBER 2016

Recent CFPB Supervisory Highlights Address FCRA Compliance Issues

Troutman Pepper Locke LLP
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The Consumer Financial Protection Bureau has continued to address FCRA-related compliance issues in its most recent Supervisory Highlights publications from March and June 2016.

United StatesConsumer Protection
David Anthony
David Anthony
Meagan Mihalko
Meagan Mihalko
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The Consumer Financial Protection Bureau has continued to address FCRA-related compliance issues in its most recent Supervisory Highlights publications from March and June 2016.  The Supervisory Highlights once again reiterate the importance of FCRA compliance for a broad spectrum of FCRA-regulated entities, including mortgage originators, furnishers of consumer information, and nationwide specialty consumer reporting agencies (NSCRAs).

June 2016 Highlights

The CFPB's June Highlights focused on FCRA requirements in the mortgage origination context.  Specifically, CFPB examiners found that one or more institutions took adverse action based on information in consumer reports but failed to provide the required FCRA disclosures.  15 U.S.C. § 1681m(a) requires a specific adverse action notice when adverse action is taken based on information contained in a consumer report.  Specifically, the notice must include: (1) the name, address, and telephone number of the CRA

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