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Event Description

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.

  • 8:30 am


    9:00 am

    Introductory Remarks

    Tiffany George
    Division of Privacy & Identity Protection, FTC

    9:05 am

    Opening Remarks

    Noah Joshua Phillips
    Commissioner, FTC

    9:15 am


    Peggy Twohig
    Assistant Director for Supervision Policy, CFPB

    “Setting the Stage – A Decade of Developments in Consumer Reporting”

    9:30 am

    Panel 1: Furnisher Practices and Compliance with Accuracy Requirements

    Leslie Bender
    Chief Strategy Officer and General Counsel, BCA Financial Services
    Francis Creighton
    President and Chief Executive Officer, Consumer Data Industry Association
    Syed Ejaz
    Policy Analyst, Consumer Reports
    Nessa Feddis
    Senior Counsel and Vice President, American Bankers Association
    Elisabeth Johnson-Crawford
    Chief Technical Officer, Credit Builders Alliance

    Susan Stocks, Office of Enforcement, CFPB & David Wake, Office of Supervision Policy, CFPB


    10:45 am


    11:00 am

    Panel 2: Current Accuracy Topics for Traditional Credit Reporting

    Roberto Cera
    Senior Manager, Data Acquisitions, TransUnion
    E. Michelle Drake
    Shareholder, BergerMontague, PC
    Troy Kubes
    Vice President and Deputy Chief Compliance Officer, Equifax
    Ed Mierzwinski
    Senior Director, Federal Consumer Programs, U.S. Public Interest Research Group
    Donna Smith
    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

    12:30 pm

    Lunch Break

    1:30 pm


    Brian Johnson
    Deputy Director, CFPB

    1:40 pm


    Andrew Stivers
    Deputy Director, Bureau of Economics, FTC

    1:50 pm

    Panel 3: Accuracy Considerations for Background Screening

    Terry W. Clemans
    Executive Director, National Consumer Reporting Association
    Eric Dunn
    Director of Litigation, National Housing Law Project
    Jamie Gullen
    Supervising Attorney, Community Legal Services
    Ariel Nelson
    Staff Attorney, National Consumer Law Center
    Melissa L. Sorenson
    Executive Director, Professional Background Screening Association
    Matt Visser
    Chief Executive Officer, VICTIG Screening Solutions

    Tiffany George & Amanda Koulousias, Division of Privacy and Identity Protection, FTC

    3:00 pm


    3:15 pm

    Panel 4: Navigating the Dispute Process

    LaDonna Bohling
    Chief Compliance Officer, Receivable Solutions
    Eric J. Ellman
    Senior Vice President, Public Policy and Legal Affairs, Consumer Data Industry Association
    Stephanie Froelich
    Chief Executive Officer, True Hire
    Kristi C. Kelly
    Attorney, Kelly & Guzzo
    Rebecca Kuehn
    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

    4:30 pm

    Closing Remarks

    Maneesha Mithal
    Associate Director, Division of Privacy & Identity Protection, FTC

  • 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.

FTC Privacy Policy

Under the Freedom of Information Act (“FOIA”) or other laws, we may be required to disclose to outside organizations the information you provide when you pre-register. The Commission will consider all timely and responsive public comments, whether filed in paper or electronic form, and as a matter of discretion, we make every effort to remove home contact information for individuals from the public comments before posting them on the FTC website.

The FTC Act and other laws we administer permit the collection of your pre-registration contact information and the comments you file to consider and use in this proceeding as appropriate.  Under the Freedom of Information Act or other laws, we may be required to disclose to outside organizations the information you provide when you pre-register.  For additional information, including routine uses permitted by the Privacy Act, see the Commission’s Privacy Act system for public records and comprehensive privacy policy.

This event will be open to the public and may be photographed, videotaped, webcast, or otherwise recorded.  By participating in this event, you are agreeing that your image — and anything you say or submit — may be posted indefinitely at or on one of the Commission's publicly available social media sites.