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On January 17, 2025, the CFPB announced that it had entered into a consent order with a credit reporting agency to resolve allegations that the agency violated the Fair Credit Reporting Act (FCRA) and the Consumer Financial Protection Act (CFPA) by purportedly conducting unreasonable investigations into consumer credit reporting disputes. In its consent order, the Bureau alleged that the agency’s investigation procedures were inadequate by, among other things, 1) failing to timely reinvestigate, and at other times entirely failing to initiate reinvestigations for consumer disputes, 2) unreasonably relying on and failing to meaningfully review responses from furnishers when investigating consumer disputes, 3) maintaining unreasonably restrictive internal procedures preventing the agency from reviewing relevant documentation from consumers during an investigation, 4) providing consumers with inaccurate and incomplete notices when it resolves disputes, 5) improperly reinserting previously deleted information that the agency had determined was inaccurate into a consumer’s file, 6) maintaining flawed systems for reviewing public records bankruptcy disputes, and 7) failing to maintain procedures to identify situations where consumers were forced to submit a dispute twice for incorrect information in the consumer’s file that the agency failed to correct. In order to resolve the allegations, the credit reporting agency agreed to implement a number of enhancements to its disputes processing policies, systems, and procedures, including: 1) implementing reasonable policies and procedures regarding reinvestigation of disputes, 2) establishing an online dispute submission portal for consumers, 3) implementing additional training for agents that take disputes, 4) establishing procedures regarding the review of furnisher submitted information, 5) establishing procedures for preventing improper reinsertion of incorrect information, 6) implementing systems and policies to identify repeat disputes submitted by consumers, 7) establishing procedures and systems for reviewing disputes involving public records of consumer bankruptcy, 8) preparing template communications for communicating dispute decisions to consumers, and 9) establishing an audit program to audit and monitor the processing of disputes. The credit reporting agency also agreed to pay a $15 million civil money penalty to the CFPB. |
