CFPB Highlights Credit Reporting Errors for Trafficking, Identity Theft Victims

The CFPB recently issued its Spring 2024 Supervisory Highlights, which focused on accuracy in credit reporting, particularly in connection with FCRA and Regulation V’s requirements regarding credit reporting for victims of human trafficking and identity theft.  The CFPB found that, between April 1, 2023, and December 31, 2023, consumer reporting agencies (CRAs) failed to ensure the accuracy of credit reports, and that furnishers failed to correct false or fraudulent information they sent to the CRAs.

Key findings in the Supervisory Highlights include the following:

• CRAs failed to block or remove information related to identity theft and human trafficking;
• CRAs accepted information from unreliable furnishers that may have been no longer providing reliable, verifiable information about consumers;
• Furnishers provided information to CRAs they knew was false, incomplete, or inaccurate, and at times even after they determined the information was fraudulent or due to identity theft; and
• Furnishers did not follow requirements for dispute investigations and identity theft, including continuing to furnish information that consumers were disputing without noting the information was in dispute.