Sending A Message: The CFPB's Charges Against TransUnion

For months, Director Rohit Chopra warned that the Consumer Financial Protection Bureau (the "Bureau") would sharpen its focus on repeat offenders.¹ On April 12, 2022, the Bureau demonstrated its resolve, announcing charges against national credit reporting agency TransUnion, two of its subsidiaries, and a long-time executive for violating a 2017 consent order that prohibited TransUnion from deceptively marketing credit scores and credit-related products.²

In January 2017, the Bureau issued a consent order against TransUnion to address findings that the credit reporting agency violated the Consumer Financial Protection Act ("CFPA") by deceptively marketing credit-related products. The consent order required TransUnion to pay $13.93 million in restitution to consumers, to pay a $3 million civil penalty, and to abide by certain conduct provisions. However, the Bureau found more than a year later during a supervisory exam that TransUnion was still using deceptive