The Federal Trade Commission and the Consumer Financial Protection Bureau (CFPB) hosted a public workshop on December 10, 2019 to discuss issues affecting the accuracy of both traditional credit reports and employment and tenant background screening reports.
Since the FTC released its 2012 study on accuracy in credit reporting, there have been several changes in the landscape that impact the accuracy of consumer reports. In 2012, the CFPB began conducting supervisory reviews over large credit reporting agencies (CRAs), as well as various providers of consumer financial products or services that furnish information about consumers to CRAs. In addition, in 2015, following state investigations regarding various credit reporting issues, the nationwide CRAs agreed to a multi-state settlement that requires stricter standards for matching records, removal of certain public record information, and restrictions on medical debt reporting. Also, new developments, such as the use of machine learning and alternative data in making eligibility determinations, present both opportunities and challenges for the consumer reporting industry.
The December workshop sought to bring together stakeholders—including industry representatives, consumer advocates, and regulators—for a wide-ranging public discussion on the many issues impacting the accuracy of consumer reports. The agencies invited interested individuals to submit comments recommending topics that should be addressed or specific information on the following potential topics for discussion:
- What are the lessons from the CFPB’s supervisory reviews of CRAs and furnishers on accuracy and dispute obligations?
- What are the lessons from CFPB and FTC enforcement cases on furnisher and CRA accuracy obligations?
- How do furnishing practices differ based on the types of furnishers and the information they furnish to CRAs, and how does that impact accuracy?
- What has been the effect of the removal of most civil judgments and tax liens from credit reports and recent changes in the reporting of medical debt?
- How do background screening CRAs address accuracy in light of the limited personal identifying information included in public records?
- What opportunities or challenges does inclusion of non-traditional data in credit reports, credit scoring models, or background screening reports present for accuracy?
- Can new technologies and data management practices be used to improve accuracy?
- How do consumers learn about inaccuracies on their consumer reports and navigate the current dispute process? What are the experiences of victims of identity theft in the dispute process?
- How have the changes to the dispute process contained in the National Consumer Assistance Plan, which evolved out of the 2015 multi-state settlement, impacted the consumer experience?
- Once consumers get erroneous information removed from their credit files through the dispute process, do they still have difficulties getting loans or other credit?
- What government measures (including changes in the law) and private sector measures could improve accuracy? What are the costs and benefits of these possible measures?
The process for submitting comments is explained below.
The workshop, which was free and open to the public, was held at the Constitution Center, 400 7th St., SW, Washington, D.C., and was webcast live on the FTC’s website.
Division of Privacy & Identity Protection, FTC
Noah Joshua Phillips
Assistant Director for Supervision Policy, CFPB
“Setting the Stage – A Decade of Developments in Consumer Reporting”
Panel 1: Furnisher Practices and Compliance with Accuracy Requirements
Chief Strategy Officer and General Counsel, BCA Financial Services
President and Chief Executive Officer, Consumer Data Industry Association
Policy Analyst, Consumer Reports
Senior Counsel and Vice President, American Bankers Association
Chief Technical Officer, Credit Builders Alliance
Susan Stocks, Office of Enforcement, CFPB & David Wake, Office of Supervision Policy, CFPB
Panel 2: Current Accuracy Topics for Traditional Credit Reporting
Senior Manager, Data Acquisitions, TransUnion
E. Michelle Drake
Shareholder, BergerMontague, PC
Vice President and Deputy Chief Compliance Officer, Equifax
Senior Director, Federal Consumer Programs, U.S. Public Interest Research Group
Chief Data Officer, Consumer Information Services, Experian North America
Michael A. Turner
President and Chief Executive Officer, Policy and Economic Research Council
Tony Rodriguez & Kiren Gopal, Office of Supervision Policy, CFPB
Deputy Director, CFPB
Deputy Director, Bureau of Economics, FTC
Panel 3: Accuracy Considerations for Background Screening
Terry W. Clemans
Executive Director, National Consumer Reporting Association
Director of Litigation, National Housing Law Project
Supervising Attorney, Community Legal Services
Staff Attorney, National Consumer Law Center
Melissa L. Sorenson
Executive Director, Professional Background Screening Association
Chief Executive Officer, VICTIG Screening Solutions
Tiffany George & Amanda Koulousias, Division of Privacy and Identity Protection, FTC
Panel 4: Navigating the Dispute Process
Chief Compliance Officer, Receivable Solutions
Eric J. Ellman
Senior Vice President, Public Policy and Legal Affairs, Consumer Data Industry Association
Chief Executive Officer, True Hire
Kristi C. Kelly
Attorney, Kelly & Guzzo
Partner, Hudson Cook
Chi Chi Wu
Staff Attorney, National Consumer Law Center
Amanda Koulousias, Division of Privacy and Identity Protection, FTC & Beth Freeborn, Bureau of Economics, FTC
Associate Director, Division of Privacy & Identity Protection, FTC
Event Speaker - File
Consumer and Business Education
Request for Comments
Comments may be submitted until January 10, 2020, electronically or in written form. If you prefer to file your comment on paper, write “Accuracy in Consumer Reporting Workshop” on your comment and on the envelope and mail your comment to the following address: Federal Trade Commission, Office of the Secretary, Constitution Center, 400 7th St., SW, 5th Floor, Suite 5610, Washington, D.C., 20024.