Yesterday, the Consumer Financial Protection Bureau (“CFPB”) made Issue 22 of its Supervisory Highlights available. This Issue covers examination topics identified between September 2019 and December 2019. One of the big topics highlighted in this Issue is consumer reporting; three areas of deficiency are identified under the Fair Credit Reporting Act (“FCRA”) and Regulation V. Specifically, the Issue address use of a consumer report without a permissible purpose, providing notice of delinquency of accounts, and duty to investigate disputes. Another topic of interest is fair lending under the Equal Credit Opportunity Act (“ECOA”), Regulation B, the Home Mortgage Disclosure Act (“HMDA”), and Regulation C. This Issue of Supervisory Highlights touches on Redlining and failure to consider public assistance income in violation of ECOA and Regulation B.
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