Metro 2, E-OSCAR and New Tougher FCRA / CFPB Compliance

Overview:

Understand your potential legal risk and compliance obligations with respect to consumer credit reporting. Many financial institutions which furnish consumer credit information on a periodic basis to Credit Reporting Agencies (CRAs) experience challenges in furnishing data in the Metro 2® format. Most credit reporting disputes are handled through the E-OSCAR/ACDV system, which has had recent updates that affect data furnishers’ legal obligations in regard to these disputes. This is an active area of litigation and regulatory scrutiny that is consistently being reviewed by examiners and regulators.

This program will be instrumental in establishing proper credit policies and procedures to comply with Federal regulations. The expert will review E-OSCAR (Electronic-Online Solution for Complete and Accurate Reporting) a CFPB requirement, pros, and cons of using METRO or METRO-2 format and any federal requirements.

This webinar will help attendees better understand their potential legal risk and compliance obligations with respect to consumer credit reporting. Special problems relating to the Metro 2 credit reporting guidelines relating to bankruptcies, disputed accounts and identity theft also will be addressed. Also, we will discuss if you should report to more than one NCRA, and why you should run quality checks on any data you report to make sure your trade lines are showing up accurately on consumer reports and that you are in compliance.

Objectives of the Presentation:

• You will be able to discuss penalties for noncompliance
• You will be able to review the credit reporting lifecycle
• You will be able to describe an executive reporting dashboard
• You will be able to describe major credit reporting compliance obligations
• You will be able to recognize potential areas of litigation risk in connection with an investigation in response to a credit reporting dispute
• You will be able to discuss Metro 2 Credit Reporting Guidelines and related obligations of CRAs and furnishers
• You will be able to explain CRAs’ and furnishers’ obligations in response to an ACDV

Why Should You Attend:

The Consumer Financial Protection Bureau will impact everyone in your institution dealing with consumers and consumers’ credit information. By understanding the obligations as it pertains to consumer credit reporting, legal risks can be mitigated more effectively and certain associated problems can be addressed and resolved more efficiently and effectively.

By attending this webinar, you will be able to describe major credit reporting compliance obligations; you will be able to recognize potential areas of litigation risk in connection with an investigation in response to a credit reporting dispute.

Areas Covered in the Session:

METRO 2 CREDIT REPORTING GUIDELINES

• Furnishers’ initial reporting obligations under 15 U.S.C. § 1681s-2(a)
• Recent FCRA and related litigation
• Reporting of accounts included in bankruptcy
  • Chapter 7
  • Chapter 13
• Reporting of accounts in dispute

E-OSCAR AND FCRA LITIGATION RISK AND COMPLIANCE BURDEN

• Recent developments in FCRA/CFPB compliance requirements
• Responding to a CRA dispute and the ACDV System (15 U.S.C. § 1681s-2(b))
  • Scope of review of consumer dispute
  • Deletion of trade lines and related obligations

HANDLING CONSUMER CLAIMS OF IDENTITY THEFT

• Review of CFPB’s Supervisory Bulletin including Furnishers Duty to Investigate Consumer Credit Report Disputes
  • All agencies will apply CFPB tougher exam standards
  • FACTA Section 312 will play a key part in your agencies expectations
  • Your responsibilities under the FACTA-Red Flag guidelines as a Data Furnisher
  • Reviewing your trade line information to be in compliance and reduce risk
• Reporting Data
  • Reporting your information monthly using the METRO or METRO-2 format
  • Using E-OSCAR to view and respond to consumer disputes- Automated Credit Dispute Verifications (ACDV Responses)
  • Using E-OSCAR to create and submit interim maintenance requests Automated Universal Data forms (AUDs) for previously reported trade lines
  • NEW Compliance points and running quality control checks
• Conclusion
  • Putting this knowledge into action & reducing your Institution’s risk!

ACTION STEPS TO IMPROVE COMPLIANCE

• Analyze Input Channels
• Servicing System to Metro 2® File Review to CRA Soft Pull
• Risk Ranking
• Remediate Issues Identified
• Establish Credit Reporting Oversight and Framework for Future State
• Update P&Ps
• Establish Ongoing Monitoring

Who Will Benefit:

• Compliance Officers
• Lenders
• Operations Personnel
• Branch Managers
• Assistant Branch Managers
• Customer Service Reps
• Consumer Lenders
• Risk Officers
• Collectors
• Auditors
• Trainers
• Everyone in your institution dealing with consumers, credit information and identity theft