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Discover your financial institution's potential legal risks (and how to mitigate them!) and compliance requirements as related to consumer credit data reporting.
If you report to a national Credit Reporting Agency (CRA), then you've probably encountered an issue with furnishing consumer credit data in the Metro 2® format. When credit-reporting disputes arise, they are usually managed via the e-OSCAR/ACDV system (E-OSCAR); however, recent updates to e-OSCAR have impacted the legal obligations of data furnishers. Because examiners and regulators consistently review and revise data reporting requirements, your financial institution is continually at risk for legal actions and regulatory scrutiny.
In this webinar, we will review problematic areas of Metro 2 credit-reporting guidelines, including issues related to the Military Lending Act (MLA), bankruptcies, disputed accounts, and more! By examining recent litigation related to e-OSCAR and the Fair Credit Reporting Act (FCRA), you will better understand your institution's potential legal risk and reporting obligations. We will discuss recent developments in the Bureau of Consumer Financial Protection's reporting requirements, so you can prepare to meet this compliance burden now, next year, and beyond! We will also review the CFPB's Supervisory Bulletin (issued in March 2017), which specifically focuses on the Furnisher's Duty to Investigate Consumer Credit Report Disputes; this will enable you to better handle consumer claims of identity theft, as well as your responsibilities under the FACTA-Red Flag guidelines. Guidance will be provided on how to review your trade line information to remain in compliance and mitigate risk. In addition, this session will suggest action steps your institution can take to improve compliance. This includes risk ranking, establishing a framework for credit reporting oversight, updating your policies and procedures, and establishing ongoing monitoring. After you attend this webinar, you will understand how to use the Metro 2 e-learning system to report consumer data to Equifax, Experian, Innovis, and TransUnion, while remaining in compliance with examiner expectations and mitigating legal risks!
- Overview of Metro 2 credit reporting guidelines
- 15 U.S.C. 1681s-2(a). Data Furnishers' Initial Credit Reporting Obligations
- Bankruptcy reporting (Chapters 7 & 13)
- Reporting disputed accounts
- Reporting in practice - examples
- Reporting your data monthly using Metro 2 format
- Using E-OSCAR to view/respond to Automated Credit Dispute Verifications (ACDV responses)
- Using E-OSCAR to create/submit Automated Universal Data forms (AUDs) for previously reported trade lines
- Current legal risks
- Recent FCRA and Regulation V litigation
- FACTA Section 312 and handling claims of identity theft
- Review of pending litigation and relevant case law
- Compliance requirements your institution should know about in 2019
- Safe harbor provisions
- Recent FCRA/CFPB compliance developments - beware of tougher exam standards!
- NEW compliance points and running quality control checks
- 15 U.S.C. § 1681s-2(b). Responding to a CRA Dispute
- Scope of review - consumer disputes
- Obligations related to deleting trade lines
- Compliance action steps
- Analyzing input channels
- Ranking risks and remediating identified issues
- Establishing framework for reporting oversight and ongoing monitoring
- Updating your P&Ps
- Review model disclosure
- Provisional topic of review: If Democrats gain control of the Senate and/or House in November, then we will review actions Congress could take to toughen exam standards, reporting guidelines, and/or other areas affecting furnishers of credit data. LEARNING OBJECTIVES
After attending this webinar, you will be able to discuss the following areas with respect to credit data reporting:
- Metro 2 guidelines and furnishers' major compliance obligations
- Penalties for noncompliance
- Litigation risks related to investigating and responding to a reporting dispute
- The lifecycle of credit data reporting
- How to enact this knowledge and reduce your institution's risk!
- Compliance officers
- Loan officers and lending staff -especially consumer lenders!
- Operations officers and staff
- Branch (and assistant branch) managers
- Customer service representatives
- Risk officers and staff
- Collections officers
- Bank auditors and auditing staff
- Bank trainers
- Other employees dealing with consumers, credit information, and/or identity theft
Credit Data Reporting Compliance
Supervisory Highlights Consumer Reporting Special Edition
Complaint snapshot: 50 state report
FAQ - Natural Declared Disaster
FAQ - Forbearance
Data Reporting Best Practices
Questions and Answers
Narrative for slide 37 and 38