John Zasada, Compliance Consulting Director, Financial Institutions Group

On April 1, 2020, the Consumer Financial Protection Bureau (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act which, among other things, eased the rules involving Fair Credit Reporting Act (FCRA) dispute requirements. The FCRA generally requires consumer reporting agencies and furnishers to investigate disputes within 30 days of receipt of the consumer’s dispute. The CFPB is extending the 30-day period to 45 days if the consumer provides additional information that is relevant to the investigation during the 30-day period.  In addition, in light of the COVID-19 pandemic, the CFPB will consider a consumer reporting agency’s or furnisher’s individual circumstances and does not intend to cite in an examination or bring an enforcement action against a consumer reporting agency or furnisher making good faith efforts to investigate disputes as quickly as possible, even if dispute investigations take longer than the statutory timeframe.