• CFPB Releases Its Procedures for Examining Consumer Reporting Companies
  • September 10, 2012 | Author: H. Keith Thomerson
  • Law Firm: Hinshaw & Culbertson LLP - Jacksonville Office
  • The Consumer Financial Protection Bureau (CFPB) has released the procedures it intends to use in examining credit bureaus and other consumer reporting companies. These procedures are allegedly a “field guide” for CFPB examiners. This coincides with media reports and indications on the CFPB website that is hiring investigators to perform surveillance on the industry.

    Per a CFPB press release, the field guide has been developed to “ensure that all companies are held to the same standards.” The CFPB indicates that its force of examiners will be determining whether consumer reporting companies are complying with requirements of federal consumer financial laws, including: (1) whether reporting companies have reasonable procedures in place to ensure accuracy of information about consumers that appears in their reports; (2) whether reporting companies are conducting reasonable investigations when consumers dispute the accuracy or completeness of their files, and whether the systems, procedures and policies used by the company for tracking, handling, investigating and resolving consumer inquiries, disputes and complaints are appropriate; (3) whether reporting companies disclose to consumers their file information and credit scores when required to do so, and whether companies have trained personnel to explain the information in their disclosures to consumers; and (4) whether companies are taking adequate protections to prevent identity theft.

    The CFPB has stated that the field guide is an important step in streamlining the process for determining whether enforcement actions will be brought “to address harm to consumers.”