Reporting of consumer information has been significantly impacted by the CARES Act.

Congress enacted the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) in response to the COVID-19 pandemic’s impact, aiming to alleviate its effects. The CARES Act imposes crucial obligations on entities that provide consumer information to credit reporting agencies concerning consumers affected by the pandemic.

Previously, the Bureau issued a statement instructing lenders to adhere to the credit reporting provisions outlined in the CARES Act. Recently, the Bureau released Frequently Asked Questions (FAQs) designed to ensure consumers receive the credit reporting safeguards mandated by the CARES Act.

These FAQs cover various aspects of the CARES Act’s credit reporting requirements, including guidelines for furnishers when reporting consumers as current, as stipulated by the CARES Act. Additionally, they clarify that reporting a consumer’s natural disaster or declared disaster status does not suffice as compliance with the CARES Act’s credit reporting standards. Furthermore, the FAQs address the Bureau’s guidance, offering temporary and targeted flexibility to credit reporting agencies (CRAs) or furnishers encountering challenges in investigating consumer disputes due to the pandemic. However, CRAs and furnishers are still accountable for conducting thorough investigations of consumer disputes promptly. The Bureau’s statement emphasizes its expectation for CRAs and furnishers to diligently investigate disputes in good faith and as expeditiously as possible.

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