COVID-19: What YOU need to know as a Data Furnisher
The spread of COVID-19 has had a significant impact across the world, and has proved to be extremely impactful to the many businesses, including the Financial Services sector. Given the ever-changing landscape of advice, recommended business practices, regulatory guidance, etc., we have assembled a variety of information that we believe could be beneficial to Data Furnishers.
As always, if you have questions regarding how these specific items potentially relate to your firm, our guidance is that you consult with your internal company risk or compliance teams, and/or your counsel, for direction. Additionally, specific Metro2 related questions should be directed to the Consumer Reporting Agency(ies) to whom you report. If you have questions with respect to the e-OSCAR application itself, please contact the e-OSCAR Help Desk at 866-696-7227 (Monday - Friday, 8:00a ET to 6:00p ET) or via email at firstname.lastname@example.org.
Consumer Financial Protection Bureau
Frequently asked questions from Data Furnishers:
e-OSCAR does not determine specific Response Due Dates for disputes handled within the e-OSCAR application. Each Consumer Reporting Agency (CRA) determines the appropriate due date for each dispute in order to allow enough time for Data Furnisher reinvestigation and response, as well as for their own internal processing in order to generate a response to the consumer within timelines mandated by the Fair Credit Reporting Act (FCRA). At this point in time, we do not anticipate any regulatory changes in the mandated timelines around Response Due Dates.
It is too early to determine what impact, if any, COVID-19 related changes to reporting could have on consumer credit dispute volume. The entire consumer dispute ecosystem will be closely monitoring dispute trends throughout the pandemic.
The e-OSCAR team cannot advise on how a Data Furnisher should report credit data to the CRA’s, either through regular Metro2 reporting or through dispute processing. We encourage Data Furnishers to consult with internal Risk &/or Compliance teams, and/or Counsel, for guidance.
As noted, we do not expect the FCRA-mandated timelines around the consumer dispute process to change as a result of the pandemic. The e-OSCAR team is currently developing an enhancement that will allow Data Furnishers the opportunity to submit account reinsertion requests on previously non-responded ACDVs.
The e-OSCAR team is developing a new capability that will allow Data Furnishers the opportunity to submit account reinsertion requests on previously non-responded ACDVs as a result of COVID-19 impacts.