"Accurate FCRA reporting during Covid-19" by Marshall T. Bell, Jonathan D. Jerison, and Jessica L. Pollet (Bloomberg Law)
Bloomberg LawMarshall T. Bell, Jonathan D. Jerison, Jessica L. Pollet
As financial institutions respond to a flurry of regulatory recommendations and mandates in response to the Covid-19 crisis, those relating to consumer reporting may be among the most difficult to decipher and operationalize. Federal and state authorities have made it clear that they expect furnishers of information to mitigate the effect of delinquencies on the credit reports of consumers affected by the pandemic.
This expectation is underscored by actions taken by regulators, attorneys general, and legislatures, the most significant of which is an amendment to the federal Fair Credit Reporting Act. Furnishers are left with a number of practical questions about how to align their credit reporting practices with Covid-19-driven changes to the FCRA. This article outlines considerations for furnishers grappling with the new reporting requirements.
Originally published in Bloomberg Law; reprinted with permission.