Grace Period for Invalid Errors
The creditor may report an account as delinquent if the amount due remains unpaid after the disclosed time frame , unless the creditor receives further written notice from the consumer that any portion of the billing error is still in dispute , and the creditor also :
• Reports the amount or account is in dispute .
• Mails or delivers a written notice to the consumer of the name and address of each person to whom the credit makes a report .
• Reports any subsequent resolution of the reported delinquency to all persons to whom the creditor has made a report .
Reassertion of Billing Errors
If a creditor fully complies with the above requirements , it has no further responsibilities if a consumer reasserts substantially the same billing error .
Enhanced Consumer Protection
The settlement reached between the CFPB and Citizens Bank represents a significant step toward ensuring fair and transparent credit card servicing practices within the financial industry . Not only did it mandate significant corrective actions to rectify one of the largest regional banks in the country ’ s credit card practices , but it also emphasized the CFPB ’ s continued steadfast commitment to compliance with federal regulations .
Institutions should use this settlement as a stern reminder of the vital role regulatory bodies play in safeguarding consumer interests and maintaining the integrity of the financial industry . If you feel as if your institution is coming up short in this area , look to our compliance specialists to assist in developing procedures to mitigate your institution ’ s risk . •••
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