On September 4, 2013, the Consumer Financial Protection Bureau (“CFPB”) issued a Bulletin warning data furnishers that they face potential disciplinary action if they do not properly review information submitted to the credit bureaus in conjunction with consumer disputes of credit report information. Last week’s Bulletin appears to have been prompted by recent changes that the nationwide credit bureaus have made to their dispute handling procedures: information submitted by consumers with disputes is now imaged and communicated to the furnisher. Data furnishers, including banks, finance companies and debt collectors, might take this opportunity to review their data furnishing policies and procedures to ensure that they take into account the additional information being provided by credit bureaus with consumer disputes and meet CFPB's supervisory expectations.

CFPB Intends a Long-Term Focus on Credit Reporting -

The Fair Credit Reporting Act (“FCRA”) obligates companies that provide information about their transactions and experiences with consumers (“data furnishers”) to consumer reporting agencies (“CRAs”), including credit bureaus, to investigate disputes about that information. The obligation arises when the consumer disputes information directly with the data furnisher, or when a CRA advises the data furnisher that it has received a dispute from the consumer.