ACA International members share insights on credit reporting from the ARM industry perspective during joint FTC/CFPB workshop.
12/10/2019 12:00
Accuracy in credit reporting is a collaborative and changing process, as evidenced by the discussion to start the Federal Trade Commission and Consumer Financial Protection Bureau’s workshop on the subject Dec. 10.
ACA International member Leslie Bender, IFCCE, CCCO, chief strategy officer and general counsel at BCA Financial Services Inc., shared her expertise on the role of data furnishers in credit reporting accuracy and opportunities and challenges as the prevalence of consumers’ data in the financial marketplace increases.
“As a data furnisher, what accuracy means is taking the time to assure we have proper policies and procedures, that we are following them and that we are monitoring our own conduct so that when we get documentation or other information that perhaps varies from what we thought was accurate information about the debt … we can conduct a reasonable investigation,” Bender, who is one of ACA’s Certified Instructors teaching on data privacy and security, said.
Tuesday’s panel followed the release of the CFPB’s Supervisory Highlights on Credit Reporting focused on compliance with the Fair Credit Reporting Act and Regulation V.
Bender said such reports as well as case studies and bulletins serve as a benchmark for data furnishers and the accounts receivable management industry.
“Clarity is enormously helpful if you are doing compliance,” Bender said.
Moderated by David Wake from the CFPB’s Office of Supervision Policy and Susan Stocks from the Office of Enforcement, the first panel in the day-long workshop, “Furnisher Practices and Compliance with Accuracy Requirements,” yielded a consensus on how data furnishers, regulators and consumer advocates can work together on credit reporting accuracy, especially as technology continues to evolve.
“I think what people forget is there are so many different players in the ecosystem of credit reporting,” said Francis Creighton, president and CEO of the Consumer Data Industry Association. “The data furnisher is very focused on existing consumer relationships and making sure everything is reported accurately. The data user is then using all of that information and trying to look at the consumer and see what their unique situation is.”
Consumers’ credit reports are also prevalent in many aspects of their lives, not just for securing a loan for a vehicle or home. Credit reports may influence their job search as well, for example, the panelists discussed—making accuracy even more important.
“Part of why we furnish data is to provide an economic picture of a consumer that is as portable as our smartphones,” Bender said. “We’re in a mobile society and we love the convenience that technology brings for us,” Bender explained. “Our credit report is something we bring with us every place we go.”
However, a “mobile society” and use of credit reports may also cause an increase in disputes. For example, if a consumer seeking a loan requests removal of inaccurate information from their report and it takes some time for the process to be complete; they could file a dispute based on timing alone.
It may take 30 to 45 days for changes to be reflected on credit reports, said panelist Elisabeth Johnson-Crawford, chief technical officer for the Credit Builders Alliance.
“The fact that it’s not an instantaneous system is the result of a lot of complaints,” Johnson-Crawford said.
Bender added that it’s critical for data furnishers and their creditor clients to have a “hand in glove relationship” to ensure accuracy.
“If we’re going to furnish data on behalf of someone else, we want to make sure we’re responsible in doing that,” Bender said.
Panelists commented on the future of credit reporting to conclude their discussion.
Bender said the industry can expect to see more state legislative action on data furnishing and credit reporting in 2020 and beyond.
“I think that more and more states will look at this and when you should furnish data,” Bender said.
Tuesday’s workshop also featured panel discussions on Current Accuracy Topics for Traditional Credit Reporting, Accuracy Considerations for Background Screening and Navigating the Dispute Process.
ACA member LaDonna Bohling, chief compliance officer for Receivables Solutions Inc., spoke on the dispute process panel concluding the workshop. Watch for additional coverage of the workshop with input from Bohling and Bender in ACA Daily.