Equifax Data Breach

New York Consumer Law Blog

Sunday, June 4, 2017

CFPB Report Details Problems, New Requirements Consumer Reporting Companies Must Implement

Some of the problems that the CFPB documented in its report include:

  • • No programs to test the accuracy of credit reports that the CRCs produced, prompting Director Cordray to remark "we were surprised to find that [the CRCs’] quality control systems were either rudimentary or virtually non-existent."
  • •Deficiencies regarding the CRCs’ relationship with furnishers and information sources such as:
    • • Insufficient monitoring and re-vetting of furnishers to ensure they were continuing to meet their legal and other obligations
    • • No policies to monitor dispute data regarding furnishers
    • • Lack of oversight of public records vendors
    • • Furnishers were rarely provided with feedback regarding data quality, and were sometimes charged fees for data-quality reports
  • • Deficiencies regarding the dispute process, leading Director Cordray to call the system "badly broken," such as:
    • • Failure to review and consider all relevant information submitted by consumers when conducting dispute reinvestigations
    • • Failure to consistently notify furnishers of disputes, as well to inform them of modifications and deletions resulting from disputes
    • • Failure to properly describe the results of dispute investigations in notices to consumers


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