CFPB Enters Consent Order and Stipulation with National Bank to Resolve Allegations of Inaccurate Furnishing of Credit Information and Dispute Investigations

On September 11, 2024 the CFPB announced that it had entered into a consent order and stipulation with a national bank, resolving allegations that the bank repeatedly furnished inaccurate credit information, and that the bank knew of the inaccuracies for a year or more before correcting them in violation of the Fair Credit Reporting Act (FCRA), its implementing regulation, Regulation V, and the Consumer Financial Protection Act of 2010 (CFPA). The consent order also resolved allegations that the bank failed to properly investigate consumer disputes.

The consent order identified several alleged different examples of situations where, despite an obligation to timely report accurate information, the bank systematically reported incorrect information, including instances of confirmed fraud, bankruptcy status, and delinquencies, among other categories of information. The CFPB also alleged that, despite the FCRA’s requirement that a credit furnisher conduct a reasonable investigation within 30 days, the bank often failed to investigate disputes sufficient to meet the “reasonable investigation standard” and within the requisite time period. Further, the CFPB alleged that the bank failed to maintain and implement appropriate policies and procedures for furnishing information.​

The stipulation entered into by the CFPB and the bank requires the bank to initiate steps to prevent future violations, as well as requires the bank to pay $7.76 million in redress to affected consumers and a $20 million civil money penalty.​​​