Our regulator has cited us for violating the Fair Credit Reporting Act. For some time, we provided consumer information that was outside of the purpose of the relationship we had with the consumer. In some cases, we had not yet established a relationship when we submitted information about the consumer to the credit reporting agency. Consequently, the regulator now says that we acted in the capacity of a consumer reporting agency.
On top of that, the regulator’s audit shows that we provided information to the credit agencies that were sometimes inaccurate, which triggered consumer complaints. When we got the complaints, we did not correct the information for all the consumers who complained. We did not do a risk assessment to determine how many credit report errors like this occurred.
I want to revise our policies and procedures to make sure this never happens again. Our attorney says we have furnisher liability under the FCRA. I need some guidance, and I hope you can give me some suggestions.
What are some suggestions to reduce furnisher liability for providing inaccurate consumer information to consumer reporting agencies?