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The entire financial services sector relies on the accuracy and integrity of the information flowing throughout the consumer reporting system. Consumer reporting agencies include nationwide agencies such as Experian, Equifax and TransUnion as well as specialty agencies, such as employment screening agencies, check verification companies, and tenant screening services.
Credit unions as furnishers of information to credit reporting agencies play a vital role in the consumer reporting system. Therefore, it came as no surprise that NCUA’s list of 2020 supervisory priorities (Letter 20-CU-01) included reviewing credit unions’ consumer reporting policies and procedures.
Section 623 of the FCRA imposes specific responsibilities on credit unions as furnishers of information to consumer reporting agencies. Generally, these responsibilities include the duties to:
The Consumer Financial Protection Bureau’s (CFPB’s) Regulation V primarily implements the FCRA with the exception of NCUA and Federal Trade Commission rules governing the proper disposal of consumer report information and the requirements that credit unions maintain a program to detect and address identity theft “red flags.”
Not all of the FCRA provisions have implementing regulations.
FCRA’s “furnisher” regulation (Regulation V, subpart E) requires credit unions to establish and implement reasonable written policies and procedures to ensure the accuracy and integrity of information it furnishes to consumer reporting agencies (“Accuracy defined”).
Regulation V, appendix E contains guidelines for developing these policies and procedures. In general, a credit union’s policies and procedures should:
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