b'Credit ReportingIn 2020, Goodwin tracked seven public enforcemententers into an agreement with a consumer to defer actions related to credit reporting or credit repairone or more loan payments, make a partial payment, services, a slight increase from the number of actionsforbear any delinquent amounts, modify a loan or tracked in 2019. Despite few new publicly announcedcontract, or where any other assistance or relief is enforcement actions, federal agencies remained activegranted to a consumer who is affected by COVID-19. in the space, including by issuing new policies andStates have followed suit in offering FCRA protections. proposing new regulations related to credit reporting. New Yorks Governor Andrew Cuomo issued a temporary executive order that, although it has since Key Trends expired, provided for payment accommodations, extension of payment due dates, and adjustment Since its creation, the CFPB has been the mostof existing loan terms, in an attempt to mitigate the dominant actor in policing credit reporting or creditadverse consequences of any negative credit reporting repair services. This year, the CFPB brought four out ofthat stems from delinquencies. The Illinois Department the seven actions concerning credit reporting relatedof Financial and Professional Regulation (IDFPR) also violations, and secured $5.35 million in civil moneyissued guidance suggesting similar steps to mitigate penalties. This years enforcement actions focused ondamage to consumers credit during the COVID-19 inaccurate credit reporting by credit furnishers, andcrisis. The IDFPR guidance is still in effect. also deceptive credit repair services and violations ofIn April, the CFPB issued a policy statement for credit the TSRs Advance-Fee prohibition, which prohibitsreporting companies and furnishers concerning charging consumers for any promised credit repaircredit reporting guidance during the COVID-19 results offered through telemarketing until six monthspandemic. This announcement came in the wake of after such promised results have been achieved.the interagency statement encouraging financial Throughout the year, the CFPB also signaled theinstitutions to work constructively with borrowers and importance of protecting consumers with respect toother customers affected by COVID-19 to meet their credit reporting during the COVID-19 pandemic andfinancial needs. The CFPBs April policy statement complying with the requirements of the CARES Act. provided more specific advice to consumer finance In March, during the wake of COVID-19, the CAREScompanies concerning their reporting obligations in Act amended the FCRA in several ways that impactedlight of the COVID-19 crisis. The statement included credit reporting entities. The CARES Act requiredthree key provisions:that, retroactive to January 21, 2020 and throughThe CFPB encouraged consumer finance July 31, 2020 or 120 days from the date the COVID-19companies to continue to furnish information to national emergency is declared over, a furnisher ofcredit reporting agencies during the crisis due to credit information who provided any type of consumerthe substantial benefits for consumers, users of accommodation to report the consumers accountconsumer reports, and the economy as a whole. as either current, or as the status reported prior to the accommodation if not previously current, for theThe CFPB expects furnishers to comply with duration of the period of the accommodation. ForCARES Act requirements that furnishers report the example, a furnisher of information could not reportpayment status for certain credit obligations as a consumers account as delinquent so long as thecurrent if payments are being made pursuant to an account was current before COVID-19 impacted theaccommodation between the lender and consumer.consumer. An accommodation under the CARES Act includes situations where the credit reporting entity 40'