Brave New World for Data Furnishers

On September 4, 2013, the Consumer Financial Protection Bureau ("CFPB") issued a Bulletin warning data furnishers that they face potential disciplinary action if they do not properly review information submitted to the credit bureaus in conjunction with consumer disputes of credit report information. Last week's Bulletin appears to have been prompted by recent changes that the nationwide credit bureaus have made to their dispute handling procedures: information submitted by consumers with disputes is now imaged and communicated to the furnisher. Data furnishers, including banks, finance companies and debt collectors, might take this opportunity to review their data furnishing policies and procedures to ensure that they take into account the additional information being provided by credit bureaus with consumer disputes and meet CFPB's supervisory expectations.