b'Credit ReportingIn 2021, Goodwin tracked just one public enforcementand enforcement tools to the full extent and with the full actions related to credit reporting or credit repairflexibility afforded by Congress. However, the rescission services. The single action tracked in 2021 representsleaves in place the policy statement provisions concerning a decrease in the number of actions tracked whenFurnishing Consumer Information Impacted by compared to 2020 (seven actions). Despite few newCOVID-19, articulating the CFPBs support for furnishers publicly announced enforcement actions, federalvoluntary efforts to provide payment relief to customers agenciesincluding most notably the CFPBremainedimpacted by the COVID-19 pandemic.active in the space, initiating enforcement actions,In November, the CFPB issued a research report issuing guidance, publishing reports, and making publicconcerning credit reporting disputes, and specifically the statementsall of which suggests that the industrydemographics of consumers impacted by such disputes. should be prepared for a higher level of activity in thisThe report is part of a series that focuses on trends in the space in the coming years. consumer financial marketplace, and uses data on various types of loans and credit card accounts opened between Key Trends 2012-2019. The report concluded that dispute flags appear to be more common for young and low-credit-In our 2020 YIR, we predicted that there would not bescore borrowers and more common in majority Black a significant increase in public enforcement actionscensus tracts. In announcing the reports finding, Director concerning credit reporting or credit repair services.Chopra emphasized that accuracy of credit reporting Though that prediction proved to be true, the CFPB andwill be a focus of the Bureau under his leadership. The FTC did remain active in this space, and that activitydirector expressed particular concern over [e]rror-appears to be laying the groundwork for an ever moreridden credit reports in minority communities which he active 2022. said are far too prevalent and may be undermining an In March 2021, the Bureau rescinded its policy statement,equitable recovery. announced in April 2020, for credit reporting companiesAlso in November 2021, the Bureau issued its first and furnishers concerning credit reporting guidanceadvisory opinion since the change in administration. during the COVID-19 pandemic. That policy statementThe advisory opinion concerned name-only matching had expressed some flexibility in terms of how the Bureauprocedures used by CRAs. Those procedures match[] would evaluate compliance with FCRA as a result of theinformation to the particular consumer who is the subject pandemic. In rescinding that policy statement, the Bureauof a consumer report based solely on whether the announce[d] its intent to exercise its supervisory andconsumers first and last names are identical or similar to enforcement authority consistent with the Dodd-Frank Actthe first and last names associated with the information, and FCRA and with the full authority afforded by Congresswithout verifying the match using additional identifying consistent with the statutory purpose and objectives ofinformation for the consumer. The Bureau said that name-the Bureau. The Bureau expressed concern that only matching is particularly likely to lead to inaccuracies [d]eclining to cite conduct that is a violation of FCRA, andin consumer reports. The opinion concludes that name-Regulation V based on the articulated principles in theonly matching is not a procedure that assures maximum [COVID-19 Guidance] may skew the consumer financialpossible accuracy, and thus consumer reporting marketplace, to the detriment of market participantsagencies that use name-only matching violate FCRA who do not act in violation. Thus, the Bureau statedsection 607(b). that it is more important than ever that institutionsFinally, the Bureaus Winter 2021 issue of Supervisory adhere to consumer protection and consumer reportingHighlights included observations of ways that CFPB requirements and that the Bureau use its supervisory 40'