In January 2018, the Congressional Research Service (CRS) issued a report, “Consumer Credit Reporting, Credit Bureaus, Credit Scoring, and Related Policy Issues”, which explores questions regarding accuracy, how long adverse information should remain on a credit file, medical debt, credit reports and employment decisions, alternative data, and security issues.
On January 24, 2020, CDIA sent a letter of opposition to the House Committee on Financial Services on the Comprehensive CREDIT Act of 2020. A bill that encapsulates six bills that did not have any hearings.
Federal Trade Commission (FTC)
In January 2020, CDIA filed a follow-up comment to the joint Accuracy in Consumer Reporting Workshop held by the FTC and CFPB in December 2019. CDIA served on two of the four panels at that workshop. CDIA filed a comment in advance of that workshop in December 2019. All comments filed in connection with that workshop are available online.
Social Security Administration
In January 2020, CDIA cosigned a letter with several other associations to the SSA to comment on an SSA Draft User Agreement (and related documents, like static website content and electronic signature requirements) for participants in the SSA’s electronic Consent Based Social Security Number Verification (“eCBSV”) Service, issued for notice and comment under the Paperwork Reduction Act. SSA continues to develop the system and implements Section 215 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018. The comments in our letter are grounded in the following: Implementation of the Banking Bill must adhere to the plain text of that statute and the clear intent of Congress. The Banking Bill was not ambiguous in describing the full range and limits of the authority granted to the SSA. That authority comprises: (1) Building eCBSV and ensuring its proper use through audits and monitoring; (2) certifying compliance with the Gramm-Leach-Bliley Act (“GLBA”); (3) enabling consumer consent, including by use of an “electronic signature,” as that term is defined in the Electronic Signatures in Global Electronic Signatures in Global and National Commerce Act (“E-SIGN Act”); and (4) recovering costs.