Understanding Consumer Credit Reporting Obligations: Metro 2, E-OSCAR and New Tougher FCRA/CFPB Compliance

OVERVIEW

Understand your potential legal risk and compliance obligations with respect to consumer credit reporting. Many financial institutions which furnish consumer credit information on a periodic basis to Credit Reporting Agencies (CRAs) experience challenges in furnishing data in the Metro 2® format.

Most credit reporting disputes are handled through the E-OSCAR/ACDV system, which has had recent updates that affect data furnishers' legal obligations in regard to these disputes. This is an active area of litigation and regulatory scrutiny that is consistently being reviewed by examiners and regulators.

WHY SHOULD YOU ATTEND

This webinar will help attendees better understand their potential legal risk and compliance obligations with respect to consumer credit reporting. Special problems related to the Metro 2 credit reporting guidelines, bankruptcies, disputed accounts and identity theft will also be addressed.

AREAS COVERED

METRO 2 CREDIT REPORTING GUIDELINES

• Furnishers' initial reporting obligations under 15 U.S.C. § 1681s-2(a)
• Recent FCRA and related litigation
• Reporting of accounts included in bankruptcy
• Chapter 7
• Chapter 13
• Reporting of accounts in dispute

E-OSCAR AND FCRA LITIGATION RISK AND COMPLIANCE BURDEN

• Recent developments in FCRA/CFPB compliance requirements
• Responding to a CRA dispute and the ACDV System (15 U.S.C. § 1681s-2(b))
• Scope of review of consumer dispute
• Deletion of trade lines and related obligations

HANDLING CONSUMER CLAIMS OF IDENTITY THEFT

• Review of CFPB's Supervisory Bulletin including Furnishers Duty to Investigate Consumer Credit Report Disputes
• All agencies will apply CFPB tougher exam standards
• FACTA Section 312 will play a key part in your agencies expectations
• Your responsibilities under the FACTA-Red Flag guidelines as a Data Furnisher
• Reviewing your trade line information to be in compliance and reduce risk
• Reporting Data Reporting your information monthly using the METRO or METRO-2 format
• Using E-OSCAR to view and respond to consumer disputes- Automated Credit Dispute Verifications (ACDV Responses)
• Using E-OSCAR to create and submit interim maintenance requests Automated Universal Data forms (AUDs) for previously reported trade lines
• NEW Compliance points and running quality control checks

CONCLUSION

• Putting this knowledge into action & reducing your Institution's risk!

ACTION STEPS TO IMPROVE COMPLIANCE

• Analyze Input Channels
• Servicing System to Metro 2 File Review to CRA Soft Pull
• Risk Ranking
• Remediate Issues Identified
• Establish Credit Reporting Oversight and Framework for Future State
• Update P&Ps 
• Establish Ongoing Monitoring

LEARNING OBJECTIVES

• You will be able to discuss penalties for non-compliance
• You will be able to review the credit reporting lifecycle
• You will be able to describe an executive reporting dashboard
• You will be able to describe major credit reporting compliance obligations
• You will be able to recognize potential areas of litigation risk in connection with investigation in response to a credit reporting dispute
• You will be able to discuss Metro 2 Credit Reporting Guidelines and related obligations of CRAs and furnishers
• You will be able to explain CRAs' and furnishers' obligations in response to an ACDV

WHO WILL BENEFIT

• Compliance Officers
• Lenders
• Operations Personnel
• Branch Managers
• Assistant Branch Managers
• Customer Service Reps
• Consumer lenders
• Risk Officers
• Collectors
• Auditors
• Trainers
• Everyone in your institution dealing with consumers, credit information and identity theft