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Freed Maxick Service Delivery Update

We have implemented a phased approach for returning to our offices that allows us to modify our approach to service delivery as situations change without any service disruptions. In the meantime and in the interest of public health and the safety of our community, our teams will continue working remotely whenever possible to provide the same high-quality service you have come to expect. Utilizing state-of-the-art technology, we are committed to meeting all of your assurance, tax, and advisory needs to help you navigate a business environment filled with challenges and opportunities. To discuss a specific need that can’t be handled remotely, please contact your Freed Maxick representative directly.

Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation C in Light of the CARES Act

By Freed Maxick on April, 6 2020
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Freed Maxick

Freed Maxick provides accounting, auditing, tax and consulting services and serves public and private companies, not-for-profits and municipalities to enhance profitability, save taxes, improve accountability and preserve wealth.

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Consumer Financial Protection Bureau Guidance on Credit Reporting

New call-to-actionThe Bureau’s statement informs lenders they must comply with the CARES Act. The Bureau’s statement also encourages lenders to continue to voluntarily provide payment relief to consumers and to report accurate information to credit bureaus relating to this relief. The continuation of reporting such accurate payment information produces substantial benefits for consumers, users of consumer reports, and the economy as a whole.

In addition, in response to staffing and resources constraints on lenders and credit bureaus due to the pandemic, the Bureau’s statement also provides flexibility for lenders and credit bureaus in the time they take to investigate disputes. The Bureau specifically states that it does not intend to cite in an examination or bring an enforcement action against firms who exceed the deadlines to investigate such disputes as long as they make good faith efforts during the pandemic to do so as quickly as possible.

The Bureau has also relaxed reporting requirements in several areas, most notably for Reg C (Home Mortgage Disclosure Act - HMDA).  While institutions should continue to collect HMDA data, the Bureau will provide information on when and how institutions will be expected to commence what would have been new quarterly HMDA data submissions.

The Bureau also will not expect the reporting of certain information related to credit card and prepaid accounts under the Truth in Lending Act, Regulation Z, and Regulation E. This includes the annual submissions concerning agreements between credit card issuers and institutions of higher education; quarterly submission of consumer credit card agreements; collection of certain credit card price and availability information; and submission of prepaid account agreements and related information.

Additionally, the following data collections are being postponed:

  • a survey of financial institutions that seeks information on the cost of compliance in connection with pending rulemaking on Section 1071 of the Dodd-Frank Act; and
  • a survey of firms providing Property Assessed Clean Energy financing to consumers for the purposes of implementing Section 307 of the Economic Growth, Regulatory Relief, and Consumer Protection Act.

For more details:

Statement on Supervisory and Enforcement Practices Regarding Quarterly Reporting Under the Home Mortgage Disclosure Act 

Statement on Supervisory and Enforcement Practices Regarding Bureau Information Collections for Credit Card and Prepaid Account Issuers

Statement on Bureau Supervisory and Enforcement Response to COVID-19 Pandemic: 

If you wish additional guidance, we are available to discuss your issues and concerns. Connect with us here or call Freed Maxick at 716.847.2651. Please keep in mind that due to the quickly changing nature of the COVID-19 pandemic, you should always discuss changes with your Freed Maxick advisor or legal counsel. 

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