CFPB: Updated FAQs under the CARES Act and FCRA

Soon after the CARES Act was enacted in early 2020, the CFPB published a Compliance Aid to help address consumer reporting requirements. The Compliance Aid was updated in June 2020. Below are some highlights.

  • Under the CARES Act amendments to the FCRA, a consumer whose account was not previously delinquent is current on their loan if they have received an accommodation and make any payments the accommodation requires.
  • If the credit obligation or account was delinquent before the CARES Act accommodation, the furnisher cannot advance the delinquent status. For example, if at the time of the accommodation the furnisher was reporting the consumer as 30 days past due, during the accommodation the furnisher may not report the account as 60 days past due. 
  • If during the accommodation the consumer brings the credit obligation or account current, the furnisher must report the credit obligation or account as current.
  • The Bureau will provide some flexibility in its supervisory and enforcement during the COVID-19 pandemic to help furnishers and consumer reporting agencies manage the challenges of the current crisis. However, it expects furnishers and consumer reporting agencies to make good faith efforts to investigate and resolve disputes under FCRA requirements as quickly as possible.
  • The CARES Act requires accommodations for consumers with a Federally backed mortgage loan (as defined in the CARES Act) who may obtain a forbearance from their mortgage servicer upon request and the borrower’s attestation of a financial hardship due to the COVID-19 emergency.
  • The automatic suspension of principal and interest payments on Federally held student loans expired on September 30, 2020.

Read the CFPB FAQs. 

 

Meet The Rehmann Team

Start typing a name ...
Searching for "{{nameQuery}}"...
Start typing an experience ...
Searching for "{{experienceQuery}}"...
Start typing a location ...
Searching for "{{locationQuery}}"...
Or view a list of team members

get rehmann expertise to drive your business in your inbox every week