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FCRA Compliance: METRO 2® CRRG Updates and Bankruptcy Furnishing Review

Date: Thursday, May 17, 2018
Time: 1:00-2:30 pm ET

Sponsored by Lorman Education Services

Registration - Live Webinar Only: $219.00

Registration - Live Webinar Plus CD Recording: $288.00


Understand your potential legal risk and compliance obligations with respect to consumer credit reporting.

The topic will focus on a review of new industry guidance and reporting requirement changes resulting from the Credit Reporting Resource Guide 2018 annual update. Discussion will also focus on a deep dive into bankruptcy furnishing, challenges, best practices and alternative reporting approaches that organizations may consider.

This material will help departments responsible for furnishing data to Consumer Reporting Agencies (CRAs) understand the Metro 2® format in more detail and how to avoid common pitfalls and mistakes during the furnishing process.

Many financial institutions that furnish consumer credit information to CRAs experience challenges in furnishing data in the industry standard Metro 2® format. There are many common pitfalls and mistakes that can occur when furnishing data to CRAs, with bankruptcy being a complex topic. The consequences for furnishing without accuracy and integrity can be severe. Changing industry guidance and requirements also requires organizations to reevaluate furnishing practices to stay compliant with furnishing expectations.

Failing to provide accurate data submissions to the CRAs under the Federal Credit Reporting Act (FCRA) and other Federal Consumer Finance laws can result in severe penalties. This information is critical for persons responsible for furnishing data to CRAs so they can ensure their submissions are accurate and in compliance with the FCRA.

Navigant has extensive experience assisting organizations of varying sizes across multiple industries and product types. As the furnishing functionality of institutions continues to mature following regulatory focus and scrutiny, the challenges that companies face will become increasingly more specific as broader systemic issues are identified and remediated. This has shown to be the case with bankruptcy furnishing.

Learning Objectives

  • You will be able to review major sections of the law and applicable regulations.
  • You will be able to discuss the Credit Reporting Resource Guide (CRRG) updates.
  • You will be able to describe furnishing, approaches and concerns of bankruptcy.
  • You will be able to recognize best practices for enhancing compliance with FCRA.

This Live Webinar Covers These Hot Issues:

1. Introduction and FCRA Overview

  • Major Sections of the Law/Applicable Regulations
  • FCRA 611 Responsibilities of CRAs
  • FCRA 623 Responsibilities of Furnishers
  • 1022 Appendix E Regulatory Expectations for Policies and Procedures
  • Brief Furnishing Overview
  • Credit Reporting Life Cycle
  • Accuracy and Integrity
  • Common Reporting Mistakes and Issues

2. 2018 Credit Reporting Resource Guide Updates

  • Review of Changes From 2017 CRRG
  • Key Points to Consider

3. Bankruptcy – Furnishing Approaches and Concerns

  • Typical Pain Points/Bankruptcy Furnishing Challenges
  • Industry Specific Observations
  • 5 Scenarios/Use Cases to Walk Through
  • Sample BK Issues and Resolution Topics
  • Best Practices

4. Q and A

  • Questions on Topics Discussed

5. Action Steps/Best Practices for Enhancing Compliance With FCRA

  • Compliance Monitoring System (CMS) Integration
  • FCRA Framework
  • Monitoring and Controls
  • Issue Identification, Root Cause Analysis and Remediation
  • Policies and Procedures

Credit Information (Sponsored by Lorman Education Services)

  • CLE
  • CPE
  • Bankers

For Detailed Credit Information page click here

Only registered attendee will receive continuing education credit.


David King, Navigant Consulting, Inc.

  • Director in the Banking, Insurance and Capital Markets practice, based out of Navigant Consulting, Inc.’s Houston, TX office
  •  Has conducted numerous current state assessments and system change implementation projects related to FCRA; the assessments include reviews of policies and procedures pertaining to disputes, furnishing and usage, an evaluation of Metro 2® files submitted by clients to the CRAs, and the testing of trade lines
  • Also supervised the teams acting as the independent consultant in consent orders issued by the CFPB related to FCRA
  • His bankruptcy projects include conducting risk and controls self-assessments and fee studies for mortgage institutions, along with corporate bankruptcy experience analyzing proof of claims, conducting preference actions, assisting with plan confirmation and filing monthly operating reports with the Court
  • Has led engagements covering risk management, compliance, data extraction and analysis, systems integration, systems development and document management
  • Certified Fraud Examiner, holds a CDIA FCRA Data Furnisher Requirements certificate of completion, and has been a team leader and project manager for compliance reviews, vendor audits and government inquiries for numerous companies across the world
  • Has been heavily involved in the development of various Navigant tools, including our online loan review tool and suite of credit reporting modules; this has involved managing business analysts and software developers, overseeing version releases, UAT, drafting business requirements documentation and designing reporting functions

Beji Varghese, Navigant Consulting, Inc.

  • Managing Director in the Banking, Insurance and Capital Markets practice of Navigant Consulting, Inc. based in the Charlotte, NC office
  • Managed multiple FCRA projects for Consumer Finance companies, including remediation engagements, assisting with regulatory response and preparation for exams related to FCRA
  • Actively involved with multiple regulatory matters including assisting clients respond to regulatory requests around mortgage servicing, FCRA and UDAAP
  • Oversaw the implementation of multiple HMDA projects include several re-statements projects
  • Written several articles around Mortgage servicing and has been a speaker with the MBA on regulatory compliance matters
  • Prior to joining Navigant, he was COO of a specialty residential mortgage servicer, where he was responsible for the firm’s infrastructure, operations and servicing system performance

T. Tabb Wyllie, Navigant Consulting, Inc.

  • Associate Director in the Banking, Insurance and Capital Markets practice based out of Navigant Consulting, Inc.’s New York City office
  • Has led multiple FCRA and credit reporting focused engagements including current state assessments, remediation efforts, furnishing system development and targeted reporting enhancement projects
  • In addition to helping clients develop or improve furnishing functions, he has performed credit reporting furnishing reviews focused on bankruptcy reporting and assisted clients establish FCRA governance frameworks
  • Deep experience assisting major financial institutions prepare for and respond to regulatory examinations across servicing and origination lending functions; Leads engagements for loan servicing gap analysis reviews, project management assistance, and regulatory compliance and exam preparedness
  • Prior to Navigant he worked for KPMG LLP where he was a member of the Risk Consulting practice
  • Holds a Certified Information Systems Auditor (CISA) designation, Certified Scrum Master (CSM), and CDIA Certificate for Data Furnishers

(Not available outside the US)