The CFPB recently published a blog post about the agency’s on-going efforts to monitor industry updates and innovation and how these changes align with regulatory obligations under the CFPB’s consumer protection laws. This post specifically highlighted using artificial intelligence (AI) and/or machine learning (ML) related to the adverse action notices that are required under the
Tuesday, June 30, 2020
1:00-2:00 p.m. ET
Experienced Troutman attorneys will take a close look at the nitty-gritty of the practical side of credit reporting during the COVID-19 pandemic and economic downturn. We will cover guidance from the Consumer Data Industry Association and very recent new guidance from the Consumer Financial Protection Bureau on the
On June 16, 2020, the Consumer Financial Protection Bureau (“CFPB”) issued a seven-page FAQ memorandum addressing some of the most critical questions for compliance with the new consumer reporting requirements of the “CARES Act”. In sum, this Compliance Aid:
A New York franchise motor vehicle dealer agreed in May to pay $1.5 million to the Federal Trade Commission to settle charges that the dealership discriminated against African-American and Hispanic consumers and engaged in other unfair and deceptive practices.
In a complaint filed in the United States District Court for the Southern District of New
The Supreme Court of New Jersey recently issued a decision that extends the applicability of the state’s Retail Installment Sales Act (“RISA”) to service contracts, even those that do not include a financing arrangement. This decision could have a wide reaching effect on companies that provide services to New Jersey consumers – companies that perhaps
The United States Court of Appeals for the Ninth Circuit recently issued two decisions regarding requirements under the Fair Credit Reporting Act for employers who wish to run background checks on potential or current employees. These decisions should prompt employers to take a look at their current background check disclosure and authorization forms to assess
COVID-19 has forced us to ask novel questions generally and look for stay-at-home order workarounds. Compliance with the Fair Credit Reporting Act (FCRA) is no different. One of the many questions that has arisen relates to the reinvestigation of disputed court records. How can this be done with limited access to court records? What should
On Friday, the Consumer Financial Protection Bureau (CFPB) published a supplement to its Spring 2019 notice of proposed rulemaking on third-party debt collection. The proposed supplemental rule addresses the collection of time-barred debt, which is debt that has run past any applicable statute of limitations.
Specifically, the proposed supplemental rule requires debt collectors to make
Shortly before the end of the year, two bills, introduced in the U.S. House of Representatives earlier in 2019, that seek to amend the Fair Credit Reporting Act (“FCRA”) were amended and reported out by the House Committee on Financial Services for consideration by the full House.
H.R. 3622, titled “Restoring Unfairly Impaired Credit
Three industry organizations filed suit against the Nevada Attorney General and the Commissioner of the Nevada Financial Institutions Division, claiming that a newly enacted Nevada law conflicts with and is preempted by federal law, including the Fair Credit Reporting Act (FCRA) and the Equal Credit Opportunity Act (ECOA). They are seeking an injunction preventing Nevada