A recent Consumer Financial Protection Bureau (CFPB) report indicated that credit reporting errors are a leading consumer complaint. Not surprisingly, these complaints have lead to an increased focus from the regulators - especially related to the obligation of furnishers to properly investigate disputed information in consumer reports. This increased focus should prompt all furnishers of credit report information, including credit unions, to review and revise their dispute procedures.
In 2013, the CFPB received 24,200 consumer complaints regarding credit report issues. Of those complaints, 73% were related to allegations of "Incorrect Information on Credit Report." The second most complained about issue was the incompleteness or inadequacy of the dispute investigation (11%). See, page 19 of the Report.
These finding have prompted the CFPB to issue two guidance documents warning furnishers of credit information about their obligations to conduct investigations of disputed information. The first was Bulletin 2013-09 on September 4, 2013, followed closely by Bulletin 2014-01 on February 27, 2014.
The CFPB's announcement of the 2013 Bulletin highlighted the need for furnishers to review "all revelant information" that is provided by the consumer reporting agency. To be compliant, this review must include documents submitted by the member as part of the initial dispute.
Credit unions should read the Bulletins and review whether their dispute procedures comply with the requirements under the Fair Credit Reporting Act.
