CFPB Cons Rpt FAQ - 7 What do furnishers need to consider when reporting consumers as current pursuant to the CARES Act?

Compliance > CARES Act
Q:   What do furnishers need to consider when reporting consumers as current pursuant to the CARES Act?
 
A:  Whenever furnishers provide information to consumer reporting agencies, they have obligations related to the accuracy and integrity of the information they furnish under the FCRA and Regulation V.5 To ensure compliance with these obligations, if furnishers are reporting information to consumer reporting agencies about a credit obligation or account that is current, they should consider all of the trade line information they furnish that reflects a consumer’s status as current or delinquent. For example, information a furnisher provides about an account’s payment status, scheduled monthly payment, and the amount past due may all need to be updated to accurately reflect that a consumer’s account is current consistent with the CARES Act. Furnishers are encouraged to ensure they understand the data fields that the consumer reporting agencies to whom they report utilize and which standard data reporting formats may apply.  
 
 
This Q&A was contained in the CFPB’s Compliance Aid, “Consumer Reporting FAQs Related to the CARES Act and COVID-19 Pandemic” updated June 16, 2020.  The Compliance Aid may be found here:  https://files.consumerfinance.gov/f/documents/cfpb_fcra_consumer-reporting-faqs-covid-19_2020-06.pdf
 

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