COVID-19 Considerations for Credit Reporting | FTI Consulting

COVID-19 Considerations for Credit Reporting

Financial Services

Forensic & Litigation Consulting

May 1, 2020

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on March 27, 2020 to provide stimulus to those adversely affected by COVID-19. Portions of this act and additional guidance from state regulators and the Consumer Financial Protection Bureau (CFPB) may have an impact on credit reporting processes.

Compliance with the Fair Credit Reporting Act (FCRA) has become a high-risk issue for financial institutions of all sizes due to increased regulatory scrutiny and enforcement actions. To date, the CFPB has issued millions of dollars in fines associated with enforcement actions for non-compliance and nearly half of all CFPB consumer complaints in 2019 related to credit reporting. FTI Consulting has experience developing customized solutions for clients to assist with FCRA compliance and furnishing data challenges, based on key areas of focus and need through three core service offerings:

  • Current State Assessment
  • Metro 2® File Analysis/Data Analytics
  • Tradeline Testing

FTI Consulting's professionals have extensive experience in the consumer lending sector, including creation of several captive finance companies, multiple securitizations over $100B, negotiations for sale of consumer receivables, and acquisitions and sales of finance subsidiaries. We have considerable expertise in all key aspects of consumer and auto lending and servicing. Our past engagements include financial advisory services to a wide array of consumer lenders, vendors, third parties, and other market participants.

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