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GFPB Alert and Message for Special Country wide CSRs
CFPB has sent warnings to several national specialised credit information services ('CRAs') and has informed them that CFPB considers that the CFPB does not comply with the Fair Credit Reporting Act ['FCRA'], which aims to provide consumers with simple and free annual credit report information and requires a 30-day reply.
GFPB has also published a bulletin on the same subject. These reminders and the Bulletin underline the importance the GFPB attaches to the FCRA's free credit assessment rules. Warnings quote several breaches of the simplified procedural requisition, including: Failure to include a toll-free number in the Yellow Pages of the CRA and on its website so that customers can obtain a free annual report; warnings direct beneficiaries to check their disclosure and information lists to verify regulatory adherence and to turn to the CFPB within 30 working days to " inform the CFPB of the action you have taken or are about to take to comply with the rules ... or, if you believe that these laws do not hold, ... to make a statement.
"3 "3 In this context, the warnings differ from those of other regulators who usually direct the addressee to check its policy or procedure but do not request a reply. In that they ask undertakings to give reasons for their action within 30 working days, these warnings are more similar to a civil investigation requirement.
CFPB's Bulletin also stresses the need to set up a "streamlined process" for ordering free annual financial statements. This bulletin describes CFPB's expectation of nation-wide special CRAs: Published clearly and unambiguously on any website related to the CRA' s retail report transaction, together with guidance on how to request disclose by any available means; to ensure that the CRA has'sufficient capability to receive inquiries from a reasonably expected level of consumers'; to collect'only as much individual information from a customer as reasonably necessary to request disclose in order to correctly identifying the consumer'; to provide'clear and easy to understand information and guidance' to customers, include but not be restricted to:
Provide a state of the art review related to the consumer's enquiry, a section of the "Help" or "Frequently Asked Questions" website and an explanation if the consumer's ID cannot be checked, with directions on how to fill out an annual enquiry for files to be disclosed; For those users who use other means to make discovery enquiries, comply with such enquiries or give guidance to users on how to use the optimised inprocess.
You can download the bulletin here: http://files.consumerfinance.gov/f/201211_cfpb_NSCRA_Bulletin.pdf.