14 CREDIT REPORTING In 2017, Goodwin followed 9 enforcement actions related to credit reporting or credit repair services, representing a slight increase from the 7 tracked in 2016. Unlike other areas, credit reporting and repair continues to be a federal focus, as all nine actions were brought by federal agencies—the CFPB brought eight of the actions, while the FTC brought one. The actions generally targeted credit reporting agencies and credit repair companies for alleged violations of the Fair Credit and Reporting Act (FCRA), the UDAAP provision of the CFPA, and the FTC Act. The CFPB alone collected civil monetary penalties totaling $15.85 million, and obtained restitution or disgorgement totaling another $18.1 million. These enforcement actions mostly involved the illegal charge of advance fees and the misrepresentation of the ability to repair consumers’ credit by repair companies, and the misrepresentation of the validity of credit scores and improper advertising practices by reporting companies. The CFPB has also increased its focus on monitoring the actions of furnishers of credit reporting information. KEY TRENDS As predicted in 2016’s year-in-review, and as LenderLaw Watch further noted last spring, the CFPB, in contrast to state agencies, has continued its efforts to pursue enforcement actions against credit repair companies and credit reporting companies. 2017 saw the CFPB increase its enforcement efforts in the area of credit reporting and repair relative to 2015 and 2016. In 2017, the Bureau brought enforcement actions against credit repair companies for requiring illegal advance fees, for falsely advertising their ability to repair consumers’ credit scores, and for misleading consumers about certain limitations of these companies’ money back guarantees. The CFPB also increased its focus on ensuring accurate credit reporting, bringing actions against both credit reporting agencies (CRAs) and furnishers of credit reporting information. The CRA and credit reporting actions involved alleged misrepresentation of the accuracy of the credit score reported, deceptive advertisement of credit monitoring services, and improper recordkeeping practices. The $15.85 million in civil money penalties the CFPB collected over eight actions represents an increase over 2016.