Meeting Credit Reporting Requirements in the Context of the Pandemic and How to Mitigate Liability Under CARES Amendments to the FCRA
Bryan A. Fratkin
Partner
McGuireWoods LLP (Richmond, VA)
Steven M. Kaplan
Practice Co-Leader, Financial Services Regulatory and Enforcement
Mayer Brown (Washington, DC)
The consumer lending industry saw a pre-COVID uptick in credit reporting disputes, with actions under the FCRA leading over any other statute. Complexities in credit reporting in the pandemic will only exacerbate this trend further. Compliance challenges and disputes resulting from retroactive CARES Act provisions preceding the enactment of the statute. This panel will speak on:
- Ambiguities in the CFPB’s guidance on credit reporting borrowers in forbearance
- Expected state enforcement over violations of federal or state reporting acts due to delays in credit reporting
- Challenges in reporting for mortgages discharged in bankruptcy