skip to navigation
skip to content

Financial Outsourcing Solutions

Corporate People

FOS Blog

13 Apr

FCRA Requirements During COVID-19

On April 1, 2020, the CFPB (Bureau) recognized that COVID-19 pandemic is having an impact on financial institutions as well as the customers they serve.  The Bureau encourages financial institutions to work with borrowers and other customers affected by the pandemic by offering payment flexibility as required by the CARES Act or voluntarily.  The borrower can take advantage of payment relief such as skip or deferred payments and not be penalized by the reporting of a late payment to credit reporting agencies (CRAs).  FCRA requires the accuracy and integrity of information reported to credit reporting agencies.  It is critical that these loans are set up on the Bank’s core system correctly to avoid reporting a payment as delinquent.  Therefore, loan servicing personnel may want to verify a sample of these loans before furnishing information to CRAs.

The statement also provided information regarding handling consumer’s disputes. The statutory timeframe is within 30 days of receipt of the consumer’s dispute; however, there is an extension to 45 days if the borrower provides additional relevant information during the 30 days.  The Bureau understands that the pandemic poses challenges and do not intend to cite in an examination or bring an enforcement action against a consumer reporting agency or furnisher that makes a good faith effort to investigate disputes as quickly as possible, even if dispute investigations take longer than the statutory timeframe.

This article as well as other regarding COVID-19 can be found on the Bureau’s website

For additional information contact the author at