Q: The CARES Act addresses accommodations to consumers impacted by COVID-19. What is an accommodation for purposes of the CARES Act amendments to the FCRA?
A: An “accommodation” includes any payment assistance or relief granted to a consumer who is affected by the COVID-19 pandemic during the period from January 31, 2020, until 120 days after the termination of the COVID-19 national emergency declared by the President on March 13, 2020 under the National Emergencies Act. Such an accommodation includes, for example, agreements to defer one or more payments, make a partial payment, forbear any delinquent amounts, or modify a loan or contract. An accommodation includes assistance or relief that is granted voluntarily or pursuant to a statutory or regulatory requirement.