Tag: data furnishers

When running a credit report on a new applicant, you must ensure Fair Credit Reporting Act (FCRA) compliance before accessing, using and sharing the collected data. The Coronavirus Aid, Relief, and Economic Security (CARES) Act has impacted credit reporting under the FCRA, as has new guidance from the Consumer Financial Protection Bureau (CFPB). Recent updates include: The CARES Act amended the FCRA to require furnishers who agree to an “accommodation,”1 to report the account as current, although it is permitted to continue to report the account as delinquent if the account was delinquent before the accommodation was made. Although not legally obligated, data furnishers should continue furnishing information to the credit reporting agencies (CRAs) during the COVID-19 crisis, and make sure that information reported is complete and accurate. Below is a brief FCRA-related compliance overview2 covering various FCRA requirements3 when requesting and using consumer credit reports for an extension of credit permissible purpose. For more information regarding your responsibilities under the FCRA as a user of consumer reports, please consult your Legal Counsel and the Notice to Users of Consumer Reports: Obligations of Users Under the FCRA handbook located on our website. Before obtaining a consumer report you have…  Reviewed your federal and state regulations and laws related to consumer reports, scores, decisions, etc.  Made sure you have a valid permissible purpose for pulling the consumer report.  Certified compliance to the CRA from which you are getting the consumer report. You have certified that you complied with all the federal and state requirements. After you take an adverse action based on a consumer report you… Provide the consumer with an oral, written or electronic notice of the adverse action. Provide written or electronic disclosure of the numerical credit score used to take the adverse action, or when providing a “risk-based pricing” notice. Provide the consumer with an oral, written or electronic notice, which includes the below information:  Name, address and telephone number of CRA that supplied the report, if nationwide. A statement that the CRA did not make the adverse decision and therefore can’t explain why the decision was made.  Notice of the consumer’s right to a free copy of their report from the CRA, if requested within 60 days.  Notice of the consumer’s right to dispute with the CRA the accuracy or completeness of any information in a consumer report provided by the CRA. Provide the consumer with a “risk-based pricing” notice if credit was granted but on less favorable terms based on information in their consumer report. We understand how challenging it is to understand and meet all your obligations as a data furnisher – we’re here to make it a little easier. Click below to speak with a representative and gain more insight on how the CARES Act impacts FCRA reporting. Download overview Speak with a representative 1An “accommodation” is defined as “an agreement to defer one or more payments, make a partial payment, forbear any delinquent amounts, modify a loan or contract, or any other assistance or relief” granted to a consumer affected by COVID-19 during the covered period. 2This FCRA overview is not legal guidance and does not enumerate all your requirements under the FCRA as a user of consumer reports. Additionally, this FCRA Overview is not intended to provide legal advice or counsel you regarding your obligations under the FCRA or any other federal or state law or regulation. Should you have any questions about your institution’s specific obligations under the FCRA or any other federal or state law or regulation, you should consult with your Legal Counsel. 3This FCRA overview is intended to be used solely by financial service providers when extending credit to consumers and does not include all FCRA regulatory obligations. You are responsible for regulatory compliance when requesting and using consumer reports, which includes adhering to all applicable federal and state statutes and regulations and ensuring that you have the correct policies and procedures in place.

Last week, the unemployment rate soared past 20%, with over 30 million job losses attributed to the COVID-19 pandemic. As a result, many consumers are facing financial stress, which has raised many questions and discussions around how credit history and reporting should be treated at this time. Since the initial start of the pandemic, credit reporting companies and data furnishers have been put under the spotlight to ensure that consumers are able to get the assistance that they need. Numerous questions and concerns have also been raised around the extent of which consumers have access to fair and affordable credit. On March 27th, 2020, Congress signed the Coronavirus Aid, Relief, and Economic Security (CARES) Act into law, which was a bill created to provide support and relief for American workers, families, and small businesses. This newly proposed Act also provides guidelines on how creditors and data furnishers should report information to credit bureaus, to ensure that lenders remain flexible as consumers navigate the current pandemic. The Act requires that creditors must provide “accommodations” to consumers affected by COVID-19 during “covered periods.” According to the National Credit Union Administration, “The CARES Act requires credit reporting agency data providers, including credit unions, to report loan modifications resulting from the COVID-19 pandemic as ‘current’ or as the status reported before the accommodation unless the consumer becomes current,” as stated in Section 4021. Section 4021 of the CARES Act also provides other guidelines for accurate data reporting. During this time, lenders can use attributes to determine risk during COVID-19. Attributes within custom scores can also capture consumer behavior and help lenders determine the best treatments. Payment attributes, debt burden attributes, inquiry attributes, credit extensions and originations are all key indicators to keep an eye on at this time as lenders monitor risk in their portfolios. Listen in as our panel of experts explore the areas related to data reporting that impact you the most. In addition to a regulatory update and discussions around programs to help support consumers and businesses, we’ll also review what other lenders are doing and early indicators of credit trends. You’ll also be able to walk away with key strategies around what your organization can do right now. Discover the latest information on: Data reporting and CDIA regulations Regulatory updates, including the CARES Act, a breakdown of Section 4021, and guidelines to remember Credit attribute trends and highlights, treatment of scores and attributes, as well as recommended attributes Watch the webinar

With new legislation, including the Coronavirus Aid, Relief, and Economic Security (CARES) Act impacting how data furnishers will report accounts, and government relief programs offering payment flexibility, data reporting under the coronavirus (COVID-19) outbreak can be complicated. Especially when it comes to small businesses, many of which are facing sharp declines in consumer demand and an increased need for capital. As part of our recently launched Q&A perspective series, Greg Carmean, Experian’s Director of Product Management and Matt Shubert, Director of Data Science and Modelling, provided insight on how data furnishers can help support small businesses amidst the pandemic while complying with recent regulations. Check out what they had to say: Q: How can data reporters best respond to the COVID-19 global pandemic? GC: Data reporters should make every effort to continue reporting their trade experiences, as losing visibility into account performance could lead to unintended consequences. For small businesses that have been negatively affected by the pandemic, we advise that when providing forbearance, deferrals be reported as “current”, meaning they should not adversely impact the credit scores of those small business accounts. We also recommend that our data reporters stay in close contact with their legal counsel to ensure they follow CARES Act guidelines. Q: How can financial institutions help small businesses during this time? GC: The most critical thing financial institutions can do is ensure that small businesses continue to have access to the capital they need. Financial institutions can help small businesses through deferral of payments on existing loans for businesses that have been most heavily impacted by the COVID-19 crisis. Small Business Administration (SBA) lenders can also help small businesses take advantage of government relief programs, like the Payment Protection Program (PPP), available through the CARES Act that provides forgiveness on up to 75% of payroll expenses and 25% of other qualifying expenses. Q: How do financial institutions maintain data accuracy while also protecting consumers and small businesses who may be undergoing financial stress at this time? GC: Following bureau recommendations regarding data reporting will be critical to ensure that businesses are being treated fairly and that the tools lenders depend on continue to provide value. The COVID-19 crisis also provides a great opportunity for lenders to educate their small business customers on their business credit. Experian has made free business credit reports available to every business across the country to help small business owners ensure the information lenders are using in their credit decisioning is up-to-date and accurate. Q: What is the smartest next play for financial institutions? GC: Experian has several resources that lenders can leverage, including Experian’s COVID-19 Business Risk Index which identifies the industries and geographies that have been most impacted by the COVID crisis. We also have scores and alerts that can help financial institutions gain greater insights into how the pandemic may impact their portfolios, especially for accounts with the greatest immediate exposure and need. MS: To help small businesses weather the storm, financial institutions should make it simple and efficient for them to access the loans and credit they need to survive. With cash flow to help bridge the gap or resume normal operations, small businesses can be more effective in their recovery processes and more easily comply with new legislation. Finances offer the support needed to augment currently reduced cash flows and provide the stability needed to be successful when a return to a more normal business environment occurs. At Experian, we’re closely monitoring the updates around the coronavirus outbreak and its widespread impact on both consumers and businesses. We will continue to share industry-leading insights to help data furnishers navigate and successfully respond to the current environment. Learn more About Our Experts Greg Carmean, Director of Product Management, Experian Business Information Services, North America Greg has over 20 years of experience in the information industry specializing in commercial risk management services. In his current role, he is responsible for managing multiple product initiatives including Experian’s Small Business Financial Exchange (SBFE), domestic and international commercial reports and Corporate Linkage. Recently, he managed the development and launch of Experian’s Global Data Network product line, a commercial data environment that provides a single source of up to date international credit and firmographic information from Experian commercial bureaus and Tier 1 partners across the globe. Matt Shubert, Director of Data Science and Modelling, Experian Data Analytics, North America Matt leads Experian’s Commercial Data Sciences Team which consists of a combination of data scientists, data engineers and statistical model developers. The Commercial Data Science Team is responsible for the development of attributes and models in support of Experian’s BIS business unit. Matt’s 15+ years of experience leading data science and model development efforts within some of the largest global financial institutions gives our clients access to a wealth of knowledge to discover the hidden ROI within their own data.  

Article written by Alex Lintner, Experian's Group President of Consumer Information Services and Sandy Anderson, Experian's Senior Vice President of Client and Sales Operations Many consumers are facing financial stress due to unemployment and other hardships related to the COVID-19 pandemic. Not surprisingly, data scientists at Experian are looking into how consumers’ credit scores may be impacted during the COVID-19 national emergency period as financial institutions and credit bureaus follow guidance from financial regulators and law established in Section 4021 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In a nutshell, Experian finds that if consumers contact their lenders and are granted an accommodation, such as a payment holiday or forbearance, and lenders report the accommodation accordingly, consumer scores will not be materially affected negatively. It’s not just Experian’s findings, but also those of the major credit scoring companies, FICO® and VantageScore®. FICO has reported that if a lender provides an accommodation and payments are reported on time consistent with the CARES Act, consumers will not be negatively impacted by late payments related to COVID-19. VantageScore® has also addressed this issue and stated that its models are designed to mitigate the impact of missed payments from COVID-19. At the same time, if as predicted, lenders tighten underwriting standards following 11 consecutive years of economic growth, access to credit for some consumers may be curtailed notwithstanding their score because their ability to repay the loan may be diminished. Regulatory guidance and law provide a robust response Recently, the Federal Reserve, along with the federal and state banking regulators, issued a statement encouraging mortgage servicers to work with struggling homeowners affected by the COVID-19 national emergency by allowing borrowers to defer mortgage payments up to 180-days or longer. The Federal Deposit Insurance Corporation stated that financial institutions should “take prudent steps to assist customers and communities affected by COVID-19.” The Office of the Comptroller of the Currency, which regulates nationally chartered banks, encouraged banks to offer consumers payment accommodations to avoid delinquencies and negative credit bureau reporting. This regulatory guidance was backed by Congress in passing the CARES Act, which requires any payment accommodations to be reported to a credit bureau as “current.” The Consumer Financial Protection Bureau, which has oversight of all financial service providers, reinforced the regulatory obligation in the CARES Act. In a statement, the Bureau said “the continuation of reporting such accurate payment information produces substantial benefits for consumers, users of consumer reports and the economy as a whole.” Moreover, the consumer reporting industry has a history of successful coordination during emergency circumstances, like COVID-19, and we’ve provided the support necessary for lenders to report accurately and consistent with regulatory guidance. For example, when a consumer faces hardship, a lender can add a code that indicates a customer or borrower has been “affected by natural or declared disaster.” If a lender uses this or a similar code, a notification about the disaster or other event will appear in the credit report with the trade line for the customer’s account and will remain on the trade line until the lender removes it. As a result, the presence of the code will not negatively impact the consumer credit score. However, other factors may impact a consumer’s score, such as an increase in a consumer’s utilization of their credit lines, which is a likely scenario during a period of financial stress. Suppression or Deletion of late payments will hurt, not help, credit scores In response to the nationwide impact of COVID-19, some lawmakers have suggested that lenders should not report missed payments or that credit bureaus should delete them. The presumption is that these actions would hold consumers harmless during the crisis caused by this pandemic. However, these good intentions end up having a detrimental impact on the whole credit ecosystem as consumer credit information is no longer accurately reflecting consumers’ specific situation. This makes it difficult for lenders to assess risk and for consumers to obtain appropriately priced credit. Ultimately, the best way to help is a consumer-specific solution, meaning one in which a lender reaches an accommodation with each affected individual, and accurately reflects that person’s unique situation when reporting to credit bureaus. When a consumer misses a payment, the information doesn’t end up on a credit report immediately. Most payments are monthly, so a consumer’s payment history with a financial institution is updated on a similar timeline. If, for example, a lender was required to suppress reporting for three months during the COVID-19 national emergency, the result would be no data flowing onto a credit report for three months. A credit report would therefore show monthly payments and then three months of no updates. The same would be true if a credit reporting agency were required to suppress or delete payment information. The lack of data, due to suppression or deletion, means that lenders would be blinded when making credit decisions, for example to increase a credit limit to an existing customer or to grant a new line of credit to a prospective customer. When faced with a blind spot, and unable to assess the real risk of a consumer’s credit history, the prudential tendency would be to raise the cost of credit, or to decrease the availability of credit, to cover the risk that cannot be measured. This could effectively end granting of credit to new customers, further stifling economic recovery and consumer financial health at a time when it’s needed most. Beyond the direct impact on consumers, suppression or deletion of credit information could directly affect the safety and soundness of the nation’s consumer and small business lending system. With missing data, lenders and their regulators would be flying blind as to the accurate information about a consumer’s risk and could result in unknowingly holding loan portfolios with heightened risk for loss. Too many unexpected losses threaten the balance of the financial system and could further seize credit markets. Experian is committed to helping consumers manage their credit and working with lenders on how best to report consumer-specific solutions. To learn more about what consumers can do to manage credit during the COVID-19 national emergency, we’ve provided resources on our website. For individuals looking to explore options their lenders may offer, we’ve included links to many of the companies and update them continuously. With good public policy and consumer-specific solutions, consumers can continue to build credit and help our economy grow.  

Many data furnishers are experiencing increases in dispute rates. It’s a tough spot to be in. Data furnishers are not only obligated under the FCRA to investigate and respond to all consumer disputes – reviewing every Automated Consumer Dispute Verification – but they must also do so within less than 30 days. As the number of disputes rise, resources become taxed and the risk of not meeting Fair Credit Reporting Act (FCRA) obligations increases. Let’s face it, consumer disputes aren’t going away, but understanding the reported data and metrics behind disputes can help data furnishers minimize them and defend reporting strategies and processes. 5 Way to Uncover Data Inaccuracy 1. Gain perspective against the industry and peers. Depending on the industry you service, the general benchmarks for dispute rates can vary. It’s important to understand where you fall in regards to dispute rates. Are you trending high or low? As an annualized average, we’ve recently experienced the following industry dispute rates through the end of the year: However, industry averages are just the tip of the iceberg. Measurement against peers can provide a clearer picture of where you fall. Are you an outlier or on par? How do you respond in comparison to peers? Are you deleting the trade as the result of the dispute at a higher rate? This could be an indicator of a systemic problem that needs addressing. 2. Implement pre-submission quality checks. Once you know where you stand, make sure your data is accurate before it heads out the door and hits the consumer’s credit report. Implement manual checks against Metro 2 rules. Build SQL queries to perform your checks. Better yet, use data validation software to automatically identify, track and remediate errors before sending the file to the bureaus. These steps can catch disputes before they happen. 3. Review any data being rejected after submission. Even if your new reporting motto is ‘know before it goes’; once the data has been transmitted, you’ll still want to monitor data being rejected due to Metro 2® errors. When data is rejected that means the update you provided did not make it to file. This leaves room for disputes. Incorporating a robust review of all rejected data in a timely and detailed manner, with updates made before the next reporting period, can improve the accuracy of your data. 4. Audit to identify and correct any stale data on file. An audit for any stale data  - which includes open accounts with a balance greater than zero that have not been updated recently - should be performed at least annually. Review, research and remediate any outdated data that could affect your customer, making it susceptible to a dispute. 5. Educate your customers. Why are your customers disputing? Are there common themes within your customer base? Often, a dispute can be eliminated before it happens, with some explanation on the way an account is reported. By providing proactive access to materials and resources that help demystify the credit reporting process, a potentially negative interaction can be turned into a positive learning opportunity, helping the overall customer experience. Learn more about data accuracy solutions.

In this age of content and increasing financial education available to all, most entities are familiar with credit bureaus, including Experian. They are known for housing enormous amounts of data, delivering credit scores and helping businesses decision on credit. On the consumer side, there are certainly myths about credit scores and the credit report. But myths exist among businesses as well, especially as it pertains to the topic of reporting credit data. How does it work? Who’s responsible? Does reporting matter if you’re a small lender? Let’s tackle three of the most common myths surrounding credit reporting and shine a light on how it really is essential in creating a healthy credit ecosystem. Myth No. 1: Reporting to one bureau is good enough. Well, reporting to one bureau is definitely better than reporting to none, but without reporting to all three bureaus, there could be gaps in a consumer’s profile. Why? When a lender pulls a consumer’s profile to evaluate it for extending additional credit, they ideally would like to see a borrower’s complete credit history. So, if one of their existing trades is not being reported to one bureau, and the lender makes a credit pull from a different bureau to use for evaluation purposes, no knowledge of that trade exists. In cases like these, credit grantors may offer credit to your customer, not knowing the customer already has an obligation to you. This may result in your customer getting over-extended and negatively impacting their ability to pay you. On the other side, in the cases of a thin-file consumer, not having that comprehensive snapshot of all trades could mean they continue to look “thin” to other lenders. The best thing you can do for a consumer is report to all three bureaus, making their profile as robust as it can be, so lenders have the insights they need to make informed credit offers and decisions. Some believe the bureaus are regional, meaning each covers a certain part of the country, but this is false. Each of the bureaus are national and lenders can report to any and all. Myth No. 2: Reporting credit data is hard. Yes, accurate and timely data reporting requires a few steps, but after you get familiar with Metro 2, the industry standard format for consumer data reporting, choose a strategy, and register for e-Oscar, the process is set. The key is to do some testing, and also ensure the data you pass is accurate. Myth No. 3: Reporting credit data is a responsibility for the big institutions –not smaller lenders and companies. For all lenders, credit bureau data is vitally important in making informed risk determinations for consumer and small business loans. Large financial institutions have been contributing to the ecosystem forever. Many smaller regional banks and credit unions have reported consistently as well. But just think how much stronger the consumer credit profile would be if all lenders, utility companies and telecom businesses reported? Then you would get a true, complete view into the credit universe, and consumers benefit by having the most comprehensive profile --- Bottom line is that when comprehensive data on consumer credit histories is readily available, it’s a good thing for consumers and lenders. And the truth is all businesses - big and small - can make this a reality.

What you give, you get. At least that is what popular philosophers claim. And if you think about it, this statement is also applicable to the world of data accuracy. As organizations of all sizes increasingly rely on data to interact with customers and create insights to drive strategy, it’s no secret bad data can quickly lead a company or financial institution down the wrong path, even landing them into regulatory troubles. A recent Experian Data Quality study found: Seventy-five percent of organizations believe inaccurate data is undermining their ability to provide an excellent customer experience. Sixty-five percent of organizations wait until there are specific issues with their data before they address and fix them. Fifty-six percent of organizations believe mistakes can be attributed to human error. For years, organizations have wanted good data simply for operational efficiencies and cost savings, but now a shift has taken place where businesses are using data for nearly every aspect of their organization. The majority of sales decisions are expected to be driven by customer data by 2020, with companies determined to turn data into actionable insight to find new customers, increase customer retention, better understand their needs, and increase the value of each customer. Additionally, the Fair Credit Reporting Act (FCRA) requires those contributing data to provide accurate and complete information to the credit reporting agencies. If they fail to meet accuracy obligations when reporting negative account histories to credit reporting companies, the result could be bureau action and fines. Organizations still deal with a high degree of inaccurate data because there are a number of challenges to maintaining it. Some of them are external forces, but many are internal challenges – most notably a reliance on reactive data management strategies. The biggest problem organizations face around data management today actually comes from within. Businesses get in their own way by refusing to create a culture around data and not prioritizing the proper funding and staffing for data management. Many businesses know they need to improve their data quality, but often have a hard time defining why an investment is needed in the current structure. Solutions exist to get in front of data accuracy challenges. DataArc 360 Powered by Experian Pandora, for example, is designed to check the consumer credit information provided by data furnishers prior to submission to credit bureaus. This allows data suppliers to take more of a proactive approach to ensuring the accuracy of information, that may result in fewer credit disputes and a more positive interaction between consumers and their credit. Creating a clear governance plan, and centralizing data management policies and policies can also clean up internal challenges and improve accuracy standards. The importance of data cannot be neglected, but again, the data has to be clean for it to matter. What you give is what you’ll get.

Ensuring the quality of reported consumer credit data is a top priority for regulators, credit bureaus and consumers, and has increasingly become a frequent headline in press outlets when consumers find their data is not accurate. Think of any big financial milestone moment – securing a mortgage loan, auto loan, student loan, obtaining low-interest rate interest credit cards or even getting a job. These important transactions can all be derailed with an unfavorable and inaccurate credit report, causing consumers to hit social media, the press and regulatory entities to vent it out. Add in the laws and increased scrutiny from the Consumer Financial Protection Bureau (CFPB), and Federal Trade Commission (FTC) and it is clear data furnishers are seeking ways to manage their data in more effective ways. At Vision 2016, I am hosting a session, Achievements in data reporting accuracy – maximizing data quality across your organization, with several panel guests willing to share their journeys and learnings attached to the topic of data accuracy. Our diverse panel features leaders from varying industries: Jodi Cook, DriveTime Alissa Hess, USAA Bank Tom Danchik, Citi Julie Moroschan, Experian Each will speak to how they’ve overcome challenges to introduce a data quality program into their respective organizations, as well as best practices around assessing, monitoring and correcting credit reporting issues. One speaker will even touch on the challenging topic of securing funding for a data quality program, considering budgets are most often allocated to strategies, products and marketing directly tied to driving revenue. All lenders are advised to maintain a full 360-degree view of data reporting, from raw data submissions to the consumer credit profile. Better data input equals fewer inaccuracies, and an overarching data integrity program, can deliver  a comprehensive view that satisfies regulators, improves the customer experience and provides better insight for internal decision making. To learn more about implementing a data quality plan for your organization, check out Vision 2016.

Accuracy matters. It matters in dart throwing, math calculations, and now more than ever, in data reporting. The Consumer Financial Protection Bureau (CFPB) issued a bulletin on Feb. 3 warning banks and credit unions that if they fail to meet accuracy obligations when reporting negative account histories to credit reporting companies, the result could be bureau action. As noted in the Fair Credit Reporting Act (FCRA) section 623, data furnishers have an obligation to ensure the accuracy of the information furnished to a Credit Reporting Agency (CRA). Violation of these rules presents a variety of risks, and the regulatory agencies have enforced harsh consequences. Avoiding penalties is certainly a strong incentive for data furnishers to implement a formal compliance management system and data quality program. But there are additional benefits to ensuring accuracy – most notably keeping customers happy and loyal, and maintaining a reputable brand in the marketplace. Today’s consumers increasingly understand the impact of credit scoring and data reporting, and recognize a poor credit score can impact their lives in major ways. Credit is tied to so many milestone financial moments. Securing mortgage loans, auto loans, obtaining low-interest rate interest credit cards and securing private student loans can all be derailed with an unfavorable and inaccurate credit report. Not to mention credit reports can influence one’s eligibility for rental housing, setting premiums for auto and homeowners insurance in some states, or determining whether to hire an applicant for a job. To properly serve customers who simply expect a fair and accurate representation of their financial history, data furnishers must be able to guarantee the credibility of their reported data. Those organizations that cannot ensure accuracy put their reputation at risk and may lose a customer’s trust and business. “Consumers should not be sidelined out of the basic banking services they need because of the flaws and limitations in a murky system,” Cordray said in the bulletin. “People deserve to have more options for access to lower-risk deposit accounts that can better fit their needs.” The CFPB has handled more than 105,000 credit-reporting complaints in its short history, making credit reporting the third most-complained-about consumer issue. By far the most common types of credit-reporting issues identified by consumers is incorrect information on credit report (77 percent).* Certainly these mistakes are not made intentionally. But speak to a consumer battling an inaccuracy, especially someone in the midst of applying for credit for a specific need, and frustrations can soar quickly. All lenders are advised to maintain a full 360-degree view of data reporting, from raw data submissions to the consumer credit profile. Better data input equals fewer inaccuracies. Additionally, there are comprehensive reporting solutions available to assess the accuracy of consumer credit data. The regulatory environment will without a doubt continue to be a hot topic in the media, fueled by announcements such as these by the CFPB, so lenders should take note and identify processes to ensure complete and utter accuracy. It matters in so many ways, so it’s best to make data reporting a priority now, if it’s not already. Source: CFPB August 2015 Monthly Complaint Report

The financial services industry continues to face mounting pressures to meet the highest standards of data reporting and accuracy. New regulations and mandates are introduced regularly, impacting the way companies do business. And a more credit-educated consumer base is seeking insights into their own credit data, providing a separate second of eyes that demand accuracy. Not only has the Fair Credit Reporting Act (FCRA) set requirements on dispute investigation and response, but the Consumer Financial Protection Bureau (CFPB) is also paying close attention. Recent announcements indicate the CFPB wants more information about the credit eco-system to gain more data about consumer disputes. According to the CFPB, it’s a joint problem – “the NCRAA’s, data furnishers, public record providers, and consumers all play roles which affect the accuracy of the information with credit reports.” And it’s not just the big banks that are being targeted with fines. The CFPB has made it clear it will also direct attention to certain nonbanks and financial products. In today’s data-driven environment, there are roughly 12,000-plus data furnishers, resulting in more than one billion pieces of information being updated on a monthly basis. Over 220 million consumers have some form of credit information attached to them, and transactional data is flowing all the time. Fail to update and a furnisher will quickly see flaws in their reporting. In fact, a recent study revealed an estimated 2.1% of contact info goes bad if unattended for more than one month. Clearly, achieving data quality is an ongoing investment for any organization, but companies often lack a clean plan. Some data furnishers fail to report, or elect to report to just one bureau, even though providing better data will result in a more complete and accurate credit profile. So how do you tackle the challenge of data quality? Organizations should consider implementing these six steps: Review data governance. Correct errors in data submissions. Complete an audit of data submissions. Evaluate disputes and resolutions. Compare data to peers and the industry. Review existing policies and processes. Follow these steps and your organization will earn a reputation among both regulators and consumers for clean, credible data. Plus, the investment in better data will reduce the need to resolve future disputes and fines. To learn more about meeting your FCRA responsibilities and best practices around data quality, check out our on-demand webinar or data integrity services site.