FCRA and Reg V: Furnishers of negative credit information

Question 1

Who do the “Furnisher rules” apply to?

Answer 1

Entities that furnish information relating to consumers to one or more consumer reporting agencies for inclusion in a consumer report

Question 2

Which entities are not considered “furnishers” (who is exempt from the rule)?

Answer 2

Entities who:
1. provide info to credit reporting agencies solely to obtain a consumer credit report
2. act as a credit reporting agency
3. Requests credit info from consumer reporting agencies
4. Is a consumer to whom the information pertains
5. Is a neighbor, friend, acquaintance or business associate of a consumer who provides info about the consumer to a consumer reporting agency in response to a specific request

Question 3

Who is required to provide a notice to the consumer that it has furnished negative information to the consumer reporting agency?

Answer 3

All financial institutions that extend credit regularly and furnish information to consumer reporting agencies

Question 4

When must the notice of furnishing negative credit information to consumer reporting agencies be disclosed?

Answer 4

Before or not less than 30 days after furnishing the information

Question 5

What is the one restriction related to disclosure timing of the notice?

Answer 5

The notice cannot be given with the initial open-end TIL disclosures

Question 6

How frequently must the notice be disclosed to the consumer?

Answer 6

Only one notice per account or per customer must be disclosed, either before or after furnishing the information