Reporting Your Credit Data : E-Oscar, METRO2, FCRA/FACTA and CFPB Compliance

    /Dr. Gina  /J. Lowdermilkspeaker of Training Doyensinvite
    Speaker: Dr. Gina J. Lowdermilk

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    Duration: 60 Minutes
    Product Code: 50246
    Level: Beginner

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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. Most credit reporting disputes are handled through the E-OSCAR/ACDV system, which has had recent updates that affect data furnishers' legal obligations in regard to these disputes. This is an active area of litigation and regulatory scrutiny that is consistently being reviewed by examiners and regulators.


This webinar will help attendees better understand their potential legal risk and compliance obligations with respect to consumer credit reporting. Special problems relating to the Metro 2 credit reporting guidelines relating to bankruptcies, disputed accounts and identity theft also will be addressed.



• Furnishers' initial reporting obligations under 15 U.S.C. § 1681s-2(a)
• Recent FCRA and related litigation
• Reporting of accounts included in bankruptcy

o Chapter 7
o Chapter 13

• Reporting of accounts in dispute


• Recent developments in FCRA/CFPB compliance requirements
• Responding to a CRA dispute and the ACDV System (15 U.S.C. § 1681s-2(b))

o Scope of review of consumer dispute
o Deletion of trade lines and related obligations


• Review of CFPB's Supervisory Bulletin including Furnishers Duty to Investigate Consumer Credit Report Disputes

o All agencies will apply CFPB tougher exam standards
o FACTA Section 312 will play a key part in your agencies expectations
o Your responsibilities under the FACTA-Red Flag guidelines as a Data Furnisher
o Reviewing your trade line information to be in compliance and reduce risk

• Reporting Data Reporting your information monthly using the METRO or METRO-2 format

o Using E-OSCAR to view and respond to consumer disputes- Automated Credit Dispute Verifications (ACDV Responses)
o Using E-OSCAR to create and submit interim maintenance requests Automated Universal Data forms (AUDs) for previously reported trade lines
o NEW Compliance points and running quality control checks

• Conclusion Putting this knowledge into action & reducing your Institution's risk!


• 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


• 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 describe major credit reporting compliance obligations
• You will be able to recognize potential areas of litigation risk in connection with investigation in response to a credit reporting dispute
• You will be able to discuss Metro 2 Credit Reporting Guidelines and related obligations of CRAs and furnishers
• You will be able to explain CRAs' and furnishers' obligations in response to an ACDV


• Compliance Officers
• Lenders
• Operations Personnel
• Branch Managers
• Assistant Branch Managers
• Customer Service Reps
• Consumer lenders
• Risk Officers
• Collectors
• Auditors
• Trainers
• Everyone in your institution dealing with consumers, credit information and identity theft


Years of Experience: 15+ years

Areas of Expertise: BSA/AML and Financial Regulatory Compliance 

Dr. Gina J. Lowdermilk, PhD (ABD), CAMS, CRMS is a qualified BSA/AML and Financial Regulatory Compliance professional with extensive policy and procedure development and implementation, training, internal audit, monitoring, risk management, and reporting experience. Her emphasis has been on working with financial institutions that are experiencing regulatory concerns and resolutions, including enforcement actions such as memorandums of understanding and cease and desist orders. Her 15 years of experience has given her the opportunity to work with small community banks to large international financial institutions. Her roles not only included BSA/AML and Compliance, but also operations, lending services, business development, marketing, management, department development, and asset quality.

Ms. Lowdermilk has worked with all of the financial regulators and examiners. She possesses advanced Microsoft Excel, PowerPoint, Word, Internet Explorer, Visio, and Access skills. She also has experience with FiServ, BAM, CRA Wiz, TeamMate, COGNOS, and Metavante banking software. Gina has been responsible for creating both recurring and ad hoc executive management and board presentations. In addition to her above experience, she is also an adjunct instructor for the business and construction management programs at a local college, as well as writes numerous BSA/AML and Compliance articles, training materials, and manuals as per clients’ requests.

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