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When Is It A Firm Offer Of Credit?

Creditors often ask when the Fair Credit Reporting Act’s (FCRA) rules relating to firm offers of credit apply. Do they apply when the creditor makes a prequalified offer? Does that change if the creditor makes a prescreened...more

CFPB CARES Act Nuance: Comment Code Alone Does Not Cut It

On Tuesday, the Consumer Financial Protection Bureau issued a Bulletin entitled Consumer Reporting FAQs Related to the CARES Act and COVID-19 Pandemic. The CFPB’s Bulletin reminds creditors that compliance with the Fair...more

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