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On January 11, the CFPB issued two new advisory
opinions (“AOs”) outlining the obligations of consumer
reporting agencies (CRAs) under the Fair Credit Reporting
Act. The Bureau has used advisory opinions to provide
regulatory guidance on FCRA compliance matters previously
and it is worth noting that in utilizing such a process the
Bureau circumvents the requirement for public notice and
comment that would be invoked in a formal rulemaking
proceeding. PBSA, nevertheless, will be responding to
the advisory opinions providing feedback both on the
substantive content of the opinions and raising concerns from a process standpoint...
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