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METRO2® Regulatory Considerations and FCRA Compliance

Date: Wednesday, September 6, 2017
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.

Many financial institutions which furnish consumer credit information on a periodic basis to Credit Reporting Agencies (CRAs) experience challenges in furnishing data in the Metro 2® format. There are many common pitfalls and mistakes that can occur when furnishing data to CRAs, and the consequences for furnishing without accuracy and integrity can be severe.

 Responding to consumer disputes in an appropriate and timely manner can also present additional complexities. 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 credit reporting agencies so they can ensure their submissions are accurate and in compliance with the FCRA.

This topic helps the persons responsible for furnishing data to CRAs and responding to disputes understand the Metro 2® format and how to avoid common pitfalls and mistakes during the furnishing process. The content provides detailed reporting examples for Metro 2® transmission along with an explanation of how to avoid incorrect submissions, and an understanding of both direct and indirect disputes.

Learning Objectives:

  • You will be able to discuss penalties for noncompliance.
  • You will be able to review the credit reporting lifecycle.
  • You will be able to describe an executive reporting dashboard.
  • You will be able to explain how to establish credit reporting oversight and framework for monitoring compliance versus future state.

This Live Webinar Covers These Hot Issues:

Introduction and Credit Reporting Overview

  • Agenda/Format and Speaker Bios/Experience
  • Key Terms
  • Major Sections of the Law/Regulations
    • FCRA 611 Responsibilities of CRAs
    • FCRA 623 Responsibilities of Furnishers
    • 1022 Appendix E Regulatory Expectations for Policies and Procedures

Regulatory Environment

  • AG Settlement With CRAs
  • CFPB Consent Orders
  • FTC Activity
  • Penalties for Noncompliance

Furnishing Overview

  • Credit Reporting Lifecycle
  • Accuracy and Integrity
  • Metro 2® Format
  • Common Pitfalls and Mistakes
  • Furnishing Examples
  • Quality Control

Disputes Overview

  • Indirect Disputes
    • Brief Overview of eOSCAR
  • Direct Disputes
  • Executive Reporting Dashboard

Action Steps to Improve Compliance

  • Analyze Input Channels
  • Servicing System to Metro 2® File Review to CRA Soft Pull
  • Risk Ranking
  • Remediate Issues Identified
  • Establish Credit Reporting Oversight and Framework for Future State
  • Update P&Ps
  • Establish Ongoing Monitoring

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.


James Christenson, Navigant Consulting, Inc.

  • Managing consultant with Navigant Consulting, Inc. in the Banking, Insurance & Capital Markets practice, the dedicated corporate finance business unit of Navigant Consulting, Inc. (NYSE:NCI)
  • Specializes in mortgage servicing compliance, financial modeling, and risk management assessments for financial institutions
  • Throughout his career he has researched, analyzed and advised on best practices across various industries and business segments
  • Extensive experience in developing and overseeing complex projects involving qualitative research and quantitative analyses to deliver transformational and sustainable outcomes
  • While at Navigant he has focused on regulation compliance within the mortgage servicing industry
  • Has completed numerous independent assessments of investor’s portfolios of defaulted mortgage loans; work has included gap analysis for loan servicing activities, developing dashboards for the monitoring of high risk processes, project management, process improvement assessments, and creating financial models and analyses
  • Recently he managed a current state assessment for large mortgage servicer/originator to review compliance with FCRA in relation to credit reporting; the FCRA work included managing tradeline testing for three servicing systems, identifying enhancements to the company’s FCRA furnishing policy, and developing a Key Risk Indicator dashboard to monitor dispute handling and furnishing data quality
  • Prior to joining Navigant Consulting he was a consultant at Berkeley Research Group LLC, a global economic consulting and expert services firm, and a Team Leader at Northern Trust Corporation, a leading provider of asset management, banking, and asset servicing solutions

Alexandra Sawyer, Navigant Consulting, Inc.

  • Associate director in the Consumer Finance practice at Navigant Consulting, Inc.
  • More than sixteen years of experience, she has a proven track record in leading a variety of engagements, including: assessing client’s current state compliance organizations; developing management regulatory compliance process, controls and procedures; managing large, complex projects; developing business strategies and reporting, data quality analysis, and system implementation
  • Experience includes assisting clients with management of compliance and risk related issues and has allowed her to successfully develop expertise in project and change management; these experiences have afforded her the opportunity to lead a number of large process improvement initiatives in the consumer services industries
  • Most recently, her experiences have allowed her to lead a number of FCRA compliance engagements; these engagements have included the assessment of organizations' current state process for the furnishing of data to Credit Reporting Agencies along with evaluation of FCRA compliance practices
  • Previously lead Credit Reporting User Acceptance Testing workstreams in support client’s furnishing system implementation
  • Prior to joining Navigant Consulting, Inc., she was with Andersen, LLP where she conducted numerous IT audit assessments in support of financial statement audits

Casey Stott, Navigant Consulting, Inc.

  • Senior associate in the Banking, Insurance and Capital Markets practice, based out of Navigant Consulting, Inc.’s Charlotte, NC office
  • More than ten years of professional experience including project management focused on compliance, operations, finance, and retail banking
  • Has an excellent track record in integrating finance, operations, risk and data analysis
  • His experience at Navigant has been primarily focused on FCRA related engagements (including multiple consent orders) for a number of large banks and auto financiers and have included comprehensive current state assessments
  • As part of these engagements, he assisted in the project management of several engagements that involved evaluation of the credit disputes process (including direct and indirect disputes), tradeline testing, user acceptance testing, root cause analysis and remediation of identified issues, data analytics, review of controls, and the assessment of furnishing policies and procedures associated with CFPB rules and regulations
  • Prior to joining Navigant he was a senior margin analyst at Morgan Stanley where he worked to limit financial and compliance risk involving asset-backed security loans and overleveraged securities accounts
  • Prior to Morgan Stanley he worked at Wells Fargo Bank as a service manager where he focused on ensuring his branch was in compliance with all state and Federal rules and regulations

Beji Varghese, Navigant Consulting, Inc.

  • Managing director in the Consumer Finance Practice of Navigant Consulting, Inc. based in Charlotte, NC
  • Specializes in the area of governance, risk and compliance and has advised multiple companies in the design and implementation of effective financial reporting internal controls
  • Worked on multiple large bank and nonbank FCRA related projects from a regulatory (CFPB focus) perspective; in addition, he has been intimately involved in helping mortgage servicers mitigate the current issues affecting their foreclosure, bankruptcy and mortgage servicing processes
  • Has led credit reporting reviews, risk and compliance reviews, distressed workouts, consent order reviews and lending best practice reviews for the top 20 US consumer finance companies
  • Can be contacted at 704-347-7639 or

T. Tabb Wyllie, Navigant Consulting, Inc.

  • Managing consultant in the Banking, Insurance and Capital Markets practice based out of Navigant Consulting, Inc.’s New York City office
  • Specializes in operational and risk related reviews for financial services clients, with recent work focusing on assisting data furnisher’s meet their FCRA obligations and other process improvement opportunities
  • Has led multiple credit reporting focused projects including current state assessments, credit reporting remediation projects, and furnishing system development and enhancement; in addition to helping clients develop or improve accurate furnishing functions, he has performed focused credit reporting furnishing reviews focused on bankruptcy reporting requirements and assisted clients establish credit reporting and FCRA governance frameworks
  • Also assisted major financial institutions prepare for and respond to regulatory examinations across servicing and origination lending functions; led engagements performing 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 senior associate in the Risk Consulting practice; at KPMG he worked with a broad range of public, private and nonprofit clients, and more specifically with financial institutions, government entities and defense contractors; typical projects included financial system development and implementation, change management, system migrations, user acceptance testing, business process analysis and improvement and training course development
  • Holds a Certified Information Systems Auditor (CISA) designation

(Not available outside the US)