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5 November 2020

CFPB Exam Findings In Summer 2020 Supervisory Highlights Related To Credit Reporting (Fair Credit Reporting Act) And Deposit Accounts (Regulations E And DD)

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Ballard Spahr LLP

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Ballard Spahr LLP—an Am Law 100 law firm with more than 750 lawyers in 18 U.S. offices—serves clients across industries in litigation, transactions, and regulatory compliance. A strategic legal partner to clients, Ballard goes beyond to deliver actionable, forward-thinking counsel and advocacy powered by deep industry experience and an understanding of each client’s specific business goals. Our culture is defined by an entrepreneurial spirit, collaborative environment, and top-down focus on service, efficiency, and results.
CFPB Exam Findings in Summer 2020 Supervisory Highlights Related to Credit Reporting and Deposit Accounts.
United States Consumer Protection
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We review the following findings and discuss their compliance implications: FCRA violations based on obtaining credit reports without a permissible purpose, incorrectly reporting the date of first delinquency, failing to conduct reasonable dispute investigations; Reg. E violations based on waivers of consumers' dispute rights, use of incorrect date to determine timeliness of error notices, providing inadequate notices of error investigation results; and Reg. DD violations based on failing to provide advertised bonuses.

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