On June 16, CFPB issued Consumer Reporting FAQs Related to the CARES Act and COVID-19 Pandemic. These FAQs follow an April 1 Statement on Supervisory and Enforcement Practices Regarding the [FCRA] and Regulation V in Light of the CARES Act. The FAQs were announced in a press release. As noted in that release,
The FAQs address the credit reporting requirements of the CARES Act, including considerations for furnishers when reporting consumers as current as required by the CARES Act. The FAQs also clarify that reporting that a consumer is affected by a natural or declared disaster is not a substitute for complying with the CARES Act credit reporting requirements. In addition, the FAQs address the Bureau’s guidance that provides temporary and targeted flexibility in the event CRAs or the furnisher experience challenges as a result of the pandemic in investigating consumer disputes. All CRAs and furnishers remain responsible for conducting reasonable investigations of consumer disputes in a timely fashion. The Bureau’s statement makes clear that the Bureau expects CRAs and furnishers to make good faith efforts to investigate disputes as quickly as possible.