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Whether you report to one or all four of the National Credit Reporting Agencies (NCRA), you are required to comply with the Fair Credit Reporting Act (FCRA) and the Fair & Accurate Credit Transaction Act (FACTA) amendment as well as the new tougher Consumer Financial Protection Bureau (CFPB) standards. It's not what you know that will hurt you-it's re-polluting the consumer's file along with some key points that can cost your Financial Institution plenty!
We will review, E-OSCAR (Electronic-Online Solution for Complete and Accurate Reporting) a CFPB requirement, pros and cons of using METRO or METRO-2 format and any federal requirements.

Also, we will discuss if you should report to more than one NCRA, and why you should run quality checks on any data you report to make sure your trade lines are showing up accurately on consumer reports and that you are in compliance.


  • You will be able to describe major credit reporting compliance obligations
  • You will be able to recognize potential areas of litigation risk in connection with investigation in response to a credit reporting dispute
  • You will be able to discuss Metro 2 Credit Reporting Guidelines and related obligations of CRAs and furnishers
  • You will be able to explain CRAs' and furnishers' obligations in response to an ACDV


By understanding the obligations as it pertains to consumer credit reporting, legal risks can be mitigated more effectively and certain associated problems can be addressed and resolved more efficiently and effectively.


METRO 2 CREDIT REPORTING GUIDELINES

  • Furnishers' initial reporting obligations under 15 U.S.C. § 1681s-2(a)
  • Recent FCRA and related litigation
  • Reporting of accounts included in bankruptcy
    • Chapter 7
    • Chapter 13
  • Reporting of accounts in dispute

E-OSCAR AND FCRA LITIGATION RISK AND COMPLIANCE BURDEN

  • Recent developments in FCRA/CFPB compliance requirements
  • Responding to a CRA dispute and the ACDV System (15 U.S.C. § 1681s-2(b))
    • Scope of review of consumer dispute
    • Deletion of tradelines and related obligations

HANDLING CONSUMER CLAIMS OF IDENTITY THEFT

  • Review of CFPB's Supervisory Bulletin including Furnishers Duty to Investigate Consumer Credit Report Disputes
    • All agencies will apply CFPB tougher exam standards
    • FACTA Section 312 will play a key part in your agencies expectations
    • Your responsibilities under the FACTA-Red Flag guidelines as a Data Furnisher
    • Reviewing your tradeline information to be in compliance and reduce risk
  • Reporting Data
    • Reporting your information monthly using the METRO or METRO-2 format
    • Using E-OSCAR to view and respond to consumer disputes- Automated Credit Dispute Verifications (ACDV Responses)
    • Using E-OSCAR to create and submit interim maintenance requests Automated Universal Data forms (AUDs) for previously reported tradelines
    • NEW Compliance points and running quality control checks
  • Conclusion
    • Putting this knowledge into action & reducing your Institution's risk!


The Consumer Financial Protection Bureau will impact everyone in your institution dealing with consumers and consumers' credit information.

  • Branch Managers
  • Assistant Branch Managers
  • Customer Service Reps
  • Lenders
  • Compliance Officers
  • Risk Officers
  • Collectors
  • Trainers


Dr. Gina J. Lowdermilk, PhD (ABD), CAMS, CRMS is a qualified BSA/AML and Financial Regulatory Compliance professional with extensive policy and procedure development and implementation, training, internal audit, monitoring, risk management, and reporting experience. Her emphasis has been on working with financial institutions that are experiencing regulatory concerns and resolutions, including enforcement actions such as memorandums of understanding and cease and desist orders. Her 15 years of experience has given her the opportunity to work with small community banks to large international financial institutions. Her roles not only included BSA/AML and Compliance, but also operations, lending services, business development, marketing, management, department development, and asset quality. Ms. Lowdermilk has worked with all of the financial regulators and examiners. She possesses advanced Microsoft Excel, PowerPoint, Word, Internet Explorer, Visio, and Access skills. She also has experience with FiServ, BAM, CRA Wiz, TeamMate, COGNOS, and Metavante banking software. Gina has been responsible for creating both recurring and ad hoc executive management and board presentations. In addition to her above experience, she is also an adjunct instructor for the business and construction management programs at a local college, as well as writes numerous BSA/AML and Compliance articles, training materials, and manuals as per clients’ requests.

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