Updated Metro 2®, e-OSCAR and the New Tougher FCRA/CFPB Compliance Requirements

Understand common furnishing challenges and issues in the accuracy and integrity of credit reporting.

Frequent updates to regulatory requirements and the necessary format for providing account- and consumer-level information to the credit reporting agencies require a constant review of the changes by data furnishers. 

Whether you report to one or all four National Credit Reporting Agencies (NCRA), you must follow the Fair Credit Reporting Act (FCRA), the Fair & Accurate Credit Transaction Act (FACTA) amendment, and the new Consumer Financial Protection Bureau (CFPB) standards. It's not so much what you know as it is re-polluting the consumer's file with some key points that can cost your Financial Institution a lot of money!
This 60-minute webinar on "Metro 2, e-OSCAR, and the New FCRA/CFPB Compliance Requirements" will be useful in developing proper credit policies and procedures to ensure compliance with Federal regulations. The expert will go over E-OSCAR (Electronic-Online Solution for Complete and Accurate Reporting), a CFPB requirement, as well as the advantages and disadvantages of using the METRO or METRO-2 format and any federal requirements.

We will also discuss whether you should report to more than one NCRA and why you should run quality checks on any data you report to ensure that your trade lines appear correctly on consumer reports and that you are in compliance.

By completing the webinar, you will be able to:

• Describe a dashboard for executive reporting
• Evaluate the credit reporting lifecycle
• Discuss the consequences of non-compliance
• Outline the most important credit reporting compliance obligations
• Recognize and identify potential areas of litigation risk associated with an investigation in response to a credit reporting dispute
• Discuss Metro 2 Credit Reporting Guidelines and CRA and furnisher obligation
• Explain the obligations of CRAs and furnishers in response to an ACDV.

METRO 2 CREDIT REPORTING GUIDELINES

Initial reporting requirements for furnishers under 15 U.S.C. § 1681s-2(a)
Recent FCRA and related litigation
Reporting of accounts subjected to bankruptcy
 • Chapter 7
 • Chapter 13
Reporting of disputed accounts

E-OSCAR AND FCRA LITIGATION RISK AND COMPLIANCE BURDEN

Recent changes to the FCRA/CFPB compliance rules
Using the ACDV System and responding to CRA disputes (15 U.S.C. § 1681s-2(b))
 • The extent of the consumer dispute review
 • Removal of tradelines and related obligations

HANDLING CONSUMER CLAIMS OF IDENTITY THEFT

Examining the CFPB's Supervisory Bulletin, which covers the duty of furnishers to look into consumer credit report disputes. 

•  All agencies will follow the CFPB's stricter exam standards.
•  The expectations of your agency will be significantly influenced by FACTA Section 312.
•  Responsibilities under the FACTA-Red Flag guidelines as a Data Furnisher
•  Examining tradeline information to be in compliance 
• Reporting Data
•  Reporting monthly information using the METRO or METRO-2 format
•  Using E-OSCAR to view and respond to consumer disputes- Automated Credit Dispute Verifications
•  Using E-OSCAR to create and submit interim maintenance of AUDs forms for previously reported tradelines
•  NEW Compliance points and running quality control checks

ANNUAL CREDIT REPORTING RESOURCE GUIDE (CRRG) UPDATES

Review the Most Recent Updates to the CRRG and How They Affect the Responsibilities of Furnishers, Including the New Guidance Related to COVID-19

• ACTIONS STEPS TO IMPROVE COMPLIANCE
• Analyse Input Channels
• Servicing System to Metro 2 File Review to CRA Soft Pull
  Risk Ranking
• Remediate Issues Identified
• Establish Credit Reporting Oversight and Framework for Future State
• Update P&Ps
• Establish Ongoing Monitoring

This webinar will assist attendees in better understanding their potential legal risk and compliance obligations regarding consumer credit reporting. Special issues concerning the Metro 2 credit reporting guidelines, such as bankruptcies, disputed accounts, and identity theft, will also be addressed.

The majority of credit reporting disputes are resolved through the E-OSCAR/ACDV system, which has recently received updates that affect data furnishers' legal obligations in these disputes.

Legal risks can be mitigated more effectively and certain associated problems can be addressed and resolved more efficiently and effectively by understanding the obligations related to consumer credit reporting.

This webinar will provide valuable insights to: 

• Compliance Officers
• Lenders
• Operations Personnel
• Branch Managers
• Assistant Branch Managers
• Customer Service Reps
• Consumer lenders
• Risk Officers
• Collectors, Auditors, Trainers
• Everyone in your institution dealing with consumers, credit information, and identity theft

Justin brings over 20 years of wide-ranging experience in compliance, training, and regulation in the financial services sector. Most recently, he served as Head of Compliance Training at Bank of China, where he led the compliance training function and created and monitored the annual training plan through a thorough training needs analysis. Previously, he served as Macquarie Group’s Head of Americas Compliance Training and J.P. Morgan Chase’s compliance training manager. He also worked for FINRA, a US regulator, where he created Examiner University to train examiners on how to perform their function.