CFPB Exam Findings in Summer 2020 Supervisory Highlights Related to Credit Reporting (Fair Credit Reporting Act) and Deposit Accounts (Regulations E and DD)

We review the following and discuss compliance implications: FCRA violations based on obtaining credit reports without a permissible purpose, incorrectly reporting the date of first delinquency, failing to conduct reasonable dispute investigations; Reg. E violations based on waivers of consumers’ dispute rights, use of incorrect date to determine timeliness of error notices, providing inadequate notices of error investigation results; and Reg. DD violations based on failing to provide advertised bonuses.