QTR . 2 | 2022
••• IN THIS ISSUE
> Spring 2022 Supervisory Highlights Released
> CFPB ’ s Concerns With Black-Box Credit Models
> FDIC Highlights Common Compliance Violations
Spring 2022 Supervisory Highlights Released
The Consumer Financial Protection Bureau ( CFPB ) released the Spring 2022 edition of its
Supervisory Highlights , summarizing pertinent legal and regulatory violations detected during the examinations , and their related enforcement actions . Doeren Mayhew has highlighted some of the most important violations below to assist your financial institution in conducting targeted testing of these areas and avoid examination findings and costly penalties .
Fair Credit Reporting Act
The Fair Credit Reporting Act ( FCRA ) requires furnishers to investigate with respect to disputed information after receiving notice of a dispute of the completeness or accuracy of any information from a consumer reporting company ( CRC ). Investigations must include a review of all relevant information provided by the CRC , and the furnisher must complete the investigation and report the results to the CRC . When disputes are forwarded to furnishers by CRCs , the FCRA does not provide the furnisher with discretion to consider them frivolous . For indirect disputes , only the CRC has discretion to determine disputes are frivolous or irrelevant .
Continued on page 2
1