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FTC/CFPB Consumer Reporting Accuracy Workshop Report

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Recently, I was honored to be a participant in the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) co-sponsored Workshop titled “Accuracy in Consumer Reporting.”

 

Terry W. Clemans is executive director of the National Consumer Reporting Association (NCRA)The Workshop featured four panel discussions, all equally balanced between industry representatives and consumer advocates, with additional featured speakers from both the FTC and CFPB. The daylong discussions focused on all aspects of consumer reporting as it pertains to the accuracy of consumer data being reported. From traditional credit transactions, collection accounts, public records of all types (civil judgments, eviction records and criminal histories which are used in resident and employment screening consumer reports) were all addressed in the sessions.

 

Accuracy of the data is an area in which the NCRA has a major interest, and has played a major role in over the years. Way back in 1993, under the National Association of Independent Credit Reporting Agencies (NCRA’s founding name), we studied the accuracy implication of the move from the then required Residential Mortgage Credit Report (RMCR) to the current standard, the automated tri-merge. That study showed that there would be very little new data found by adding the third national credit bureau file, and significantly lost data from eliminating the RMCR requirements in the quest for speed and cheaper reports. Fast-forward nearly 30 years and those findings were upheld.

 

In 2002, the largest credit reporting accuracy study still ever conducted was performed by NCRA and the Consumer Federation of America, examining more than 1.2 million live tri-merge consumer reports and scores in three various size phases. We saw areas of concern, which Congress acted to address in 2003 with the passing of Fair and Accurate Credit Transactions Act (FACTA). FACTA created the annual credit report Web site that provided consumers a free copy of their credit report for the first time without some type of adverse credit action happening to them, along with many other changes to improve the industry.

 

Most recently, the sweeping reforms known as the National Consumer Assistance Plan (NCAP) rolled out in 2015 incrementally over a three-year period made further changes that have increased the accuracy of consumer credit reports. NCAP eliminated areas that were problematic, and created new ways to improve other long time challenges. Of the multiple changes NCAP created, one of the most notable was the wholesale elimination of civil judgments from the national credit bureau databases. With the loss of Personal Identifying Information (PII) like Social Security Numbers and date of birth from many of those records, matching them to the proper consumer became inconsistent to a level in which they were removed from the system.

 

Panel One addressed the credit furnisher practices and compliance with accuracy requirements, featuring Panelists Leslie Bender, chief strategy officer and general counsel with BCA Financial Services; Francis Creighton, president and chief executive officer with the Consumer Data Industry Association; Syed Ejaz, policy analyst with Consumer Reports; Nessa Feddis, senior counsel and vice president with the American Bankers Association (ABA); Elisabeth Johnson-Crawford, chief technical officer with Credit Builders Alliance; and Moderators Susan Stocks, office of enforcement with the CFPB and David Wake of the Office of Supervision Policy with the CFPB.

 

All of the data in consumer reports start from a source of many types. Traditional creditors, collection agencies, private and government public record sources to name the most common. This group addressed some issues with each that set the foundation for future panels.

 

The opening of the Workshop was provided by Tiffany George, a senior attorney with the FTC Division of Privacy and Identity Protection, specifically focused on our industry. FTC Commissioner Noah Joshua Phillips and Peggy Twohig, Assistant Director for Supervision Policy for the CFPB both provided remarks with long-time industry regulator Twohig’s address, “Setting the Stage–A Decade of Developments in Consumer Reporting” really hit the mark laying the framework for the sessions to come.

 

Panel Two addressed the current accuracy topics for traditional credit reporting featuring Panelists Roberto Cera, senior manager of data acquisitions for TransUnion; E. Michelle Drake, shareholder with BergerMontague PC; Troy Kubes, vice president and deputy chief compliance officer with Equifax; Ed Mierzwinski, senior director of federal consumer programs with the U.S. Public Interest Research Group; Donna Smith, chief data officer with consumer information services for Experian North America; Michael A. Turner, president and chief executive officer with the Policy and Economic Research Council; with Moderators Tony Rodriguez and Kiren Gopal from the Office of Supervision Policy of the CFPB.

 

This panel did a deeper dive into the traditional credit trade lines, the vast majority of most consumer report data that source is the creditors who furnish the information about their consumers to the credit bureaus.

 

After lunch, Brian Johnson, Deputy Director of the CFPB and Andrew Stivers, Deputy Director of the Bureau of Economics for the FTC, made remarks to recap the morning sessions, set up the day, and underline the importance of this industry to our nation’s economic health. Those remarks led into Panel Three, addressing “Accuracy Considerations for Background Screening.” Those panelists were: Terry Clemans, executive director of the National Consumer Reporting Association (NCRA); Eric Dunn, director of litigation for the National Housing Law Project; Jamie Gullen, supervising attorney with Community Legal Services; Ariel Nelson, staff attorney with the National Consumer Law Center; Melissa L. Sorenson, executive director for the Professional Background Screening Association; Matt Visser; chief executive officer with VICTIG Screening Solutions; along with Moderators Tiffany George and Amanda Koulousias from the Division of Privacy and Identity Protection for the FTC.

 

Background consumer reports have a major impact on consumer ability to obtain rental housing and employment and is in need of help in the areas of missing and inconsistent data coming from the sources, the various types of municipal, states and private sources who collect, store and provide that information for reporting. 

 

Panel Four addressed “Navigating the Dispute Process,” and featured Panelists LaDonna Bohling, chief compliance officer with Receivable Solutions; Eric J. Ellman, senior vice president of public policy and legal affairs with the Consumer Data Industry Association; Stephanie Froelich, chief executive officer with True Hire; Kristi C. Kelly, and attorney with Kelly & Guzzo; Rebecca Kuehn, a partner with Hudson Cook; Chi Chi Wu, a staff attorney with the National Consumer Law Center; and Moderators Amanda Koulousias of the Division of Privacy and Identity Protection with the FTC and Beth Freeborn of the Bureau of Economics with the FTC. The proper handling of consumer disputes is the battleground of consumer accuracy. Wrong data harms everyone, and unfortunately, there those trying to beat the system via identity theft and other methods that will dispute accurate items as inaccurate. Complicating matters worse is the credit repair firms, most of which use highly questionable and sometimes illegal practices to remove any derogatory items, regardless of legitimacy.

 

The day’s closing remarks were provided by Maneesha Mithal, Associate Director of the Division of Privacy & Identity Protection with the FTC. Maneesha made several interesting reflections on the day and discussed how this Workshop and the written comments submitted both prior to and through Jan. 30, 2020 will be digested by both agencies and lay the groundwork for future FTC and CFPB actions in the consumer reporting industry over the coming months. The current consumer reporting system is a robust and accurate one, however, there is always room for improvement.

 

It is very gratifying as a very active, long-time industry participant to see that so much has improved in the quality of consumer reporting over the past 30 years. The level of accuracy and the speed in which a consumer disputes are both processed vastly better today than in the past. All segments of the industry continue to improve the system that is regarded as the best in the world, and a key element of the world’s strongest economy. While the credit reporting system is not perfect, and it never will be, something that Sen. Proxmire realized back in 1970 with the original FCRA—we as an industry should be proud of the changes that we have advanced to benefit all Americans.



 Peggy Twohig, Assistant Director for Supervision Policy for the CFPB, presents “Setting the Stage–A Decade of Developments in Consumer Reporting”
Peggy Twohig, Assistant Director for Supervision Policy for the CFPB, presents “Setting the Stage–A Decade of Developments in Consumer Reporting”

 

Panel One Moderators Susan Stocks of the CFPB with David Wake of the FTC

Panel One Moderators Susan Stocks of the CFPB with David Wake of the FTC

 

 

Nessa Feddis of the American Bankers Association and Elisabeth Johnson-Crawford from Credit Builders Alliance share their thoughts on compliance
Nessa Feddis of the American Bankers Association and Elisabeth Johnson-Crawford from Credit Builders Alliance share their thoughts on compliance

 

Nessa Feddis of the American Bankers Association and Elisabeth Johnson-Crawford from Credit Builders Alliance share their thoughts on compliance
Francis Creighton from the Consumer Data Industry Association and Syed Ejaz from Consumer Reports address attendees during the opening panel discussion

 

Panel Two Moderators Tony Rodriguez and Kiren Gopal from the Office of Supervision Policy of the CFPB took a closer look at traditional credit trade lines

Panel Two Moderators Tony Rodriguez and Kiren Gopal from the Office of Supervision Policy of the CFPB took a closer look at traditional credit trade lines

 

Troy Kubes of Equifax shares his insight during the second panel discussion

Troy Kubes of Equifax shares his insight during the second panel discussion

 

Panelist Roberto Cera of TransUnion discusses traditional credit reporting

Panelist Roberto Cera of TransUnion discusses traditional credit reporting

 

Ed Mierzwinski of the US Public Interest Research Group discusses traditional credit reporting during his Panel Two session

Ed Mierzwinski of the US Public Interest Research Group discusses traditional credit reporting during his Panel Two session

 

Donna Smith of Experian North America shares her thoughts on traditional credit reporting

Donna Smith of Experian North America shares her thoughts on traditional credit reporting

 

Brian Johnson, Deputy Director of the CFPB, highlights how the Bureau enforces its mandates

Brian Johnson, Deputy Director of the CFPB, highlights how the Bureau enforces its mandates

 

The panelists of Panel Three: Accuracy Considerations for Background Screening

The panelists of Panel Three: Accuracy Considerations for Background Screening

 

Eric Dunn of the National Housing Law Project explains the role of his firm
Eric Dunn of the National Housing Law Project explains the role of his firm

 

Melissa L. Sorenson of the Professional Background Screening Association shares her thoughts during the “Accuracy Considerations for Background Screening” panel

Melissa L. Sorenson of the Professional Background Screening Association shares her thoughts during the “Accuracy Considerations for Background Screening” panel

 

Panel Three’s Matt Visser of VICTIG Screening Solutions explains the screening process

Panel Three’s Matt Visser of VICTIG Screening Solutions explains the screening process

 

Chi Chi Wu of the National Consumer Law Center takes part in the “Navigating the Dispute Process” discussion

Chi Chi Wu of the National Consumer Law Center takes part in the “Navigating the Dispute Process” discussion

 

Rebecca Kuehn of the law firm of Hudson Cook details the legalities of the dispute process

Rebecca Kuehn of the law firm of Hudson Cook details the legalities of the dispute process

 

Eric J. Ellman of the Consumer Data Industry Association

Eric J. Ellman of the Consumer Data Industry Association

 

Eric J. Ellman of the Consumer Data Industry Association

Panel Four Moderators Amanda Koulousias and Beth Freeborn of the FTC

 

Tiffany George, Senior Attorney with the FTC delivers her Opening Remarks

Tiffany George, Senior Attorney with the FTC delivers her Opening Remarks


 

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TML announce launch of new residential Lumi products

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Steve Griffiths TML





A new, Lumi-branded, residential product has been launched by The Mortgage Lender, following a rise in demand from borrowers who have been financially impacted by the pandemic.

TML say that the range is available up to 75% loan to value, across four Lumi categories and caters for customers with defaults, CCJs, and mortgage arrears. It also offers enhanced credit criteria for unsecured arrears, bankruptcy and payday loans when compared to TML’s core range.

Lumi products are available for employed, self-employed and complex income applicants. The minimum loan is £25,001 and the maximum loan is £1m with rates starting at 4.98% for a two-year fix and 5.29% for a five-year fix at 70% loan to value.

Steve Griffiths, The Mortgage Lender sales and product director, said: “Now more than ever lenders need to have criteria that caters for a wide range of customer circumstances and recognise that the last 12 months has been financially difficult for many people.

“Our Lumi range, which is available through specialist distributors, takes a pragmatic approach to the real-world experience many of our broker partners are presented with when they are sourcing a mortgage for their clients.

“It offers fair rates combined with a flexible approach to underwriting that provides a stepping-stone for home-movers or those remortgaging and, in some cases, credit repair.”

Doug Hall, 3mc director, adds: “We are seeing increasing numbers of customers whose financial situation has been impacted by the Coronavirus pandemic who need products that are appropriate for their circumstances now.

“Through sharing our knowledge and challenges with lenders, like TML, the specialist lending sector is proving it can meet those needs in a responsible way. The launch of Lumi is great news for brokers and customers. It shows lenders are listening and able to respond to the market, improving customer choice and competition.”

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how to boost a bad credit rating

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HOLLAND, Mich. — Your credit score is just a number, but it can make a difference in your ability to get a loan, house, or even a job ,and after a tough year for finances, now is an important time to pay attention to your score.

“You need to have options, and you need to be able to have access, and all of that boils right back down to your credit score,” says Bree Austin-Roberts, a credit expert and founder of Lakeshore Credit Management and Repair Services in Holland. “I think it was a reality check for a lot of people to saying, ‘Hey, it’s time for me to start thinking about my financial situation.’”

Bree’s story is similar to so many of her clients. A few years ago, before she founded her credit repair business, she and her family were evicted from their apartment. Searching for a house and facing homelessness, Bree noticed a similar roadblock everywhere she looked.

“The credit became a problem,” she said. “It always boiled back down to the credit.”

Bree buckled down on payments and in no time had raised her credit score enough to move her family into a home and start up her business. Now helping others achieve the same success, Bree says a few simple adjustments can make a big difference. Her first call was to the three major credit bureaus to check the accuracy of her score.

“Like 80 percent of people in the United States have something that’s inaccurate on their credit report, but a lot of people don’t know because they don’t monitor their credit.”

So start by checking with TransUnion, Equifax and Experian on the accuracy of your score.

If you’re having a tough time making payments this year on bills or installment loans (which Bree says you should always have at least one of), try contacting your creditors to see if they can delay payments or work out some sort of payment plan that works for you.

“Directly related to the pandemic, a lot of lenders are being very lenient,” said Bree.

In addition to making all your monthly credit card payments on time when you can, Bree says it also matters how often you use your credit card, and on what. She says most repair experts will recommend you keep your card usage below 30 percent, but Bree recommends a lower limit for her clients.

“When you’re in the building process, you want to keep it 10 percent or below,” she said. “If you’re planning on making a major purchase in like 30 to 60 days, you probably want to keep your credit card balances between 1 and 3 percent.”

Other tips include becoming an authorized user on a loved one’s credit card. If they have good credit, spending responsibly on their account could help boost your score faster. Just have them ask their bank or credit union about adding you as an authorized user.

You can also open a secured card on your own. A secured credit card is essentially a prepaid card that ensures you don’t miss payments.

And remember: no credit doesn’t mean good credit. Lenders want to see you can responsibly handle debt.

“Having something to report is positive, but it’s the amount that reports that shows your credit worthiness,” said Bree.

What it boils down to, Bree says, is having good habits and sticking to them. Building or rebuilding credit is a marathon, not a sprint, and Bree says patience is key.

“I was never always a credit expert. It was trial and error,” she said. “I have been there before, and it doesn’t take much to end up right back there again if you’re not budgeting well–if you’re not being credit conscious.”

You can reach Bree at [email protected] or on her website or her Facebook and use the hashtags #lakeshoreCredit and #CreditQueen to join the conversation with her.

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Adam Reich On His Journey From A Bodybuilder To Building His Own Empire And Making People Financially Independent

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Adam Reich

Adam Reich was born on December 17th, 1985, and brought up in Long Island, New York. Gym and fitness lover, Adam Reich, founder of True Credit Repair, Passive Profits Ecom Automation, ReinventU wellness center, and Health Supplements didn’t always have it all. He found a great deal of success in bodybuilding competitions when he was young. He was falling short of turning professional and thus, in the time that he had, he built a late online personal training business with over 100 subscription-based clients. In 2014, Adam Reich was blessed with twin daughters and a few months later, he had to go take up a job for the New York City department of corrections on Rikers Island. He worked 16 hours a day for 5 years straight surrounded by a bunch of violent people. It was an unsafe job. Adam Reich got fed up and decided to invest all the little money he had onto himself. He worked hard and invested all of his time to finally have something of his own and he did, not just one but multiple companies with 7 figure turnovers.

Adam believes that the success he has had by far is because of the client relations and the results and satisfaction that he and his company have given over time. He believes that he should treat his clients exactly how he would expect to be treated as a customer himself. The reason behind investing in a credit repair agency was because Adam Reich first paid to have his credit repaired by the same parent company and 4 months later his credit soared from 550 to 740 and that opened a plethora of financial opportunities for himself. All of his companies are driven by customer satisfaction. He has learned that he must never over-promise to make a sale. He provides a service to his clients that he is proud of but sometimes he tends to over-deliver but he has learned from his past mistakes. Adam Reich believes that delivering a product is important but what’s more important is building a brand along with a reputation as this would help him and his company in the longer run.

Since Adam Reich realized his worth was more than that 9 to 5 job, within 6 months, he left the prior job to invest in himself, moved to Boca with his family, and built a beautiful life in South Florida. It has been great for Adam since then as he has been able to increase his salary tenfold and all the credit goes to his determination and hard work. He also worked towards making it easier for his clients to change their financial situation by providing them with abundant opportunities. That’s all that Adam has always wanted, to help others better their situations. He has had the time to experience a 9-5 job and knows how it feels to miss important events and not being able to spend time with family because of lack of financial freedom which is why he has built this empire so that nobody else has to go through what he went through.

Adam Reich has always kept his priorities straight and his clients are everything to his brand. He goes out and about for them and relates with each individual. He believes in the saying, “show me your friends and I’ll show you you’re future” and that’s why he surrounds himself with the right people always. Since he moved down to South Florida from New York, he has made sure to keep the right people beside him who give him the motivation he strived for. Adam Reich even met his fellow investors at that time and is friends with them. These are the people he used to look up to and hoped to become like them one day. To the colleagues in his industry, Adam Reich wants to mention that people should focus their energy more on customer service. Building results and winning client’s trust is very important to go far ahead in this business.

 

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