CFPB FCRA Consent Order with Auto Lender

The CFPB recently issued a consent order against an auto lender that allegedly violated FCRA and Regulation V by submitting erroneous consumer loan data to credit reporting agencies. The consent order imposes a $4,750,000 civil money penalty along with other requirements.

According to the consent order, the auto lender allegedly provided inaccurate information about consumers’ credit to the CRAs which it then failed to promptly correct.  The lender also allegedly failed to provide the CRAs with accurate Dates of First Delinquency for delinquent or charged-off accounts as required by FCRA. Additionally, the CFPB alleges, the lender violated Regulation V by failing to establish and implement written policies and procedures concerning the accuracy and integrity of information provided to the CRAs.

The terms of the consent order require, among other things, that the lender correct the inaccuracies it previously reported and take certain steps to ensure the accuracy of the consumer information it provides to the CRAs in the future. Among these required steps is a monthly review of consumer information for accuracy prior to reporting the information to the CRAs and the establishment of written policies and procedures regarding the accuracy and integrity of consumer information provided to the CRAs.

The lender neither admits nor denies the CFPB’s findings, except the facts necessary to establish the CFPB’s jurisdiction.