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How the TransUnion v. Ramirez decision and the CFPB are impacting FCRA Legal and Compliance Activity
Cadwalader partner Rachel Rodman will participate in an upcoming webinar presented by the American Bar Association that focuses on the Fair Credit Reporting Act and the roles and responsibilities of consumer reporting agencies.
This program outlines a few key considerations and best practices:
- Maintaining appropriate documentation including policies and procedures aligned with FCRA and current processes
- Conducting reasonable investigations of disputes
- Documenting all furnishing business rules including any deviations from the Metro 2® guide
- Furnishing Quality Control and testing on at least a monthly basis
- Performing data analytics on the full furnishing file
- Sample testing of tradelines
- Conducting dispute investigations with complaint tracking and analysis
- Tracking both direct and indirect volumes by dispute/complaint type and aging of disputes and complaints
- Identifying systemic issues with credit reporting processes if there are upticks in certain dispute and complaint types
- Change management
