Collector - July 2017 - 19

"In one enforcement action, the CFPB found that a
furnisher violated Regulation V, in part, by failing to
retain documentation related to disputes."

not understand the necessary consumer
protection laws. A robust training policy
may ward off future violations of the
FCRA. Furnishers should consider how the
frequency of training is determined, who
receives the training, whether the training
tracked or logged and if the training is
specific to credit reporting practices.
Finally, several of the 13 components refer
to general business interactions. Furnishers
need to examine their relationships with
clients and have policies in place to ensure a
chain of compliance from the source of the
information to the consumer report itself.
If the furnisher engages a service provider
in its credit reporting process, the furnisher
must exercise appropriate oversight of the
service provider.
Policies and procedures should address
how the furnisher notifies the service
provider of an inaccuracy, what steps the
service provider must take, and the time
frame for completing such steps.
Furnishers also need to consider
how information is furnished for
accounts involved in corporate mergers,
acquisitions or sales, to prevent re-aging
and duplicative reporting. For instance,
furnishers should consider how they
ensure the buyer and seller are not both
reporting the same information and that

the proper Metro 2 reporting codes for
assignments and transfers are being used.
While this article addresses much of the
guidance found in Appendix E, furnishers
must carefully review all of the guidance
provided within Appendix E. Remember,
policies and procedures that fail to address
these and other applicable guidelines found
within Appendix E fail to comply with
Regulation V.
By requiring furnishers to establish and
implement adequate written policies and
procedures, Regulation V helps furnishers
cultivate a dynamic, living document that
changes with the regulatory landscape and
a company's evolution. It also provides a
certain amount of protection from liability.
To achieve this end result, furnishers
must review their policies on a regular
basis to determine if they are still
appropriate to the nature, size, complexity
and scope of their business, or to
incorporate any new requirements under
the law. Furnishers are also wise to review
enforcement actions and guidance put out
by regulatory agencies and compare this
information with their current business
practices.
Laura Dadd is ACA International's
compliance analyst.

Want to know more? Check out ACA SearchPoint at
WWW.ACAINTERNATIONAL.ORG/SEARCHPOINT
for additional info on the FCRA and CRAs.

COLLECTOR 07.17

KEYNOTES

1

Agencies that furnish
information to CRAs are
required to comply with
Regulation V in the same
manner as the FCRA.

2

Regulation V and
Appendix E require
furnishers to establish
written policies and
procedures regarding the
accuracy and integrity
of consumer information
provided to CRAs.

3

Keeping up with recent
enforcement actions
and guidance put out by
regulatory agencies can
ensure your policies and
procedures will meet their
expectations.
19


http://WWW.ACAINTERNATIONAL.ORG/SEARCHPOINT

Table of Contents for the Digital Edition of Collector - July 2017

Upfront
Industry News
Best Practices
FYI
Collection Tips
What’s in Your Policy?
State Licensing Laws: What’s New and Trending
The Question of Rule 68
Calendar
Honor Roll
Healthcare Data at Risk
ACA Members Meet in D.C. to Advocate on Behalf of Industry
Fixing What’s Broken
Credit Listening Considerations
U.S. Supreme Court Hands Collection Industry a Win in ACA-Supported Case
Compliance
ACA SearchPoint
Last Word
Collector - July 2017 - Cover1
Collector - July 2017 - Cover2
Collector - July 2017 - 1
Collector - July 2017 - 2
Collector - July 2017 - Upfront
Collector - July 2017 - Industry News
Collector - July 2017 - 5
Collector - July 2017 - 6
Collector - July 2017 - 7
Collector - July 2017 - Best Practices
Collector - July 2017 - 9
Collector - July 2017 - FYI
Collector - July 2017 - 11
Collector - July 2017 - Collection Tips
Collector - July 2017 - 13
Collector - July 2017 - What’s in Your Policy?
Collector - July 2017 - 15
Collector - July 2017 - 16
Collector - July 2017 - 17
Collector - July 2017 - 18
Collector - July 2017 - 19
Collector - July 2017 - State Licensing Laws: What’s New and Trending
Collector - July 2017 - 21
Collector - July 2017 - 22
Collector - July 2017 - 23
Collector - July 2017 - The Question of Rule 68
Collector - July 2017 - 25
Collector - July 2017 - 26
Collector - July 2017 - 27
Collector - July 2017 - Calendar
Collector - July 2017 - Honor Roll
Collector - July 2017 - Healthcare Data at Risk
Collector - July 2017 - 31
Collector - July 2017 - ACA Members Meet in D.C. to Advocate on Behalf of Industry
Collector - July 2017 - 33
Collector - July 2017 - 34
Collector - July 2017 - 35
Collector - July 2017 - Fixing What’s Broken
Collector - July 2017 - 37
Collector - July 2017 - 38
Collector - July 2017 - 39
Collector - July 2017 - Credit Listening Considerations
Collector - July 2017 - 41
Collector - July 2017 - U.S. Supreme Court Hands Collection Industry a Win in ACA-Supported Case
Collector - July 2017 - 43
Collector - July 2017 - Compliance
Collector - July 2017 - 45
Collector - July 2017 - ACA SearchPoint
Collector - July 2017 - 47
Collector - July 2017 - Last Word
Collector - July 2017 - Cover3
Collector - July 2017 - Cover4
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