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CUNA Regulatory Comment Call

August 9, 2004

• The Federal Reserve Board (Fed) and the Federal Trade Commission (FTC) are conducting a joint study on the adequacy of investigations by furnishers of consumer information, including credit unions, that is reported to the credit bureaus when consumers dispute the information. The study is required under the Fair and Accurate Credit Transactions (FACT) Act and will examine the extent and manner in which credit bureaus and furnishers of consumer information are complying with the procedures, timelines, and requirements under the Fair Credit Reporting Act for:
  • The prompt investigation of disputed information.
  • The completeness of information provided to credit bureaus.
  • The prompt correction or deletion of any inaccurate or incomplete information or information that cannot be verified.

• In connection with the study, the Fed and the FTC are requesting public comment on a number of questions, including the following:
  • Of disputes received by the furnisher, what percentage of those disputes or complaints comes through a credit bureau, directly from consumers, or from other sources?
  • Do furnishers provide addresses for consumers to use to dispute information directly with the furnishers?
  • What are the procedures and timelines furnishers use for handling and investigating disputes and complaints from consumers?
  • Do consumers and credit bureaus provide sufficient information to furnishers or is information often missing? How are disputes resolved if relevant information is missing?
  • What are consumers’ experiences in resolving disputes?
  • How do furnishers ensure compliance with statutory requirements regarding accuracy and completeness of information?
  • How do credit bureaus provide furnishers with notices and relevant information when disputes are communicated directly with the credit bureaus?
  • What guidelines or procedures apply to information that continues to be disputed after the conclusion of the formal dispute process?
  • What are the furnisher’s procedures and timelines for notifying a credit bureau that a consumer has voluntarily closed a credit account with the furnisher?
  • What legislative or regulatory changes should be made with regard to investigations of disputed information?

• Comments are due by September 17, 2004. If you would like a copy of the request, please access it on the Internet at the following address, which also provides detailed information on how to submit comments:
  
  http://www.federalreserve.gov/boarddocs/press/bcreg/2004/20040805/attachment.pdf
• Please provide CUNA with a copy of your comments. You may fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.coop and to Assistant General Counsel Jeff Bloch at jbloch@cuna.coop; or mail them to Mary and Jeff in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601.