Jan. 12, 2024: Recent CFPB Updates


CFPB Addresses Inaccurate Background Check Reports and Sloppy Credit File Sharing Practices

Today, the Consumer Financial Protection Bureau (CFPB) issued guidance to consumer reporting companies to address inaccurate background check reports, as well as sloppy credit file sharing practices. The two advisory opinions seek to ensure that the consumer reporting system produces accurate and reliable information and does not keep people from accessing their personal data. First, an advisory opinion on background check reports highlights that those reports must be complete, accurate, and free of information that is duplicative, outdated, expunged, sealed, or otherwise legally restricted from public access. Second, an advisory opinion on file disclosure highlights that people are entitled to receive all information contained in their consumer file at the time they request it, along with the source or sources of the information contained within, including both the original and any intermediary or vendor source.


Today, the CFPB announced the annual adjustments for inflation to the CFPB’s civil penalty amounts, as required by the Federal Civil Penalties Inflation Adjustment Act, as amended.  This final rule is effective on January 15, 2024.

You can access the final rule at: https://www.consumerfinance.gov/rules-policy/final-rules/civil-penalty-inflation-annual-adjustments/.


CFPB Report Identifies Challenges Faced by Borrowers in Resumption of Student Loan Payments

The Consumer Financial Protection Bureau (CFPB) published an issue spotlight today on the CFPB’s oversight of student loan servicing practices in the early months of the resumption of federal student loan repayments after over three years of a payment pause due to the COVID-19 emergency. Borrowers are encountering long hold times when trying to reach their student loan servicer, experiencing significant delays in application processing times for income-driven repayment plans, and receiving inaccurate billing statements and disclosures.


The CFPB is pleased to announce that the filing period for HMDA data collected in 2023 opened on January 1, 2024. Submissions will be considered timely if received on or before Friday, March 1, 2024. The HMDA Platform provides financial institutions an opportunity to determine whether their loan/application register (LAR) data comply with the reporting requirements outlined in the Filing Instructions Guide for HMDA data collected in 2023.

Submit your data

Access the HMDA Platform to begin the filing process for data collected in 2023 here:  https://ffiec.cfpb.gov/filing/.

Users will receive a confirmation email upon submission of their HMDA data. The confirmation email will be sent to the email account of the user that has submitted the data.

Testing your submission?

The Beta Platform found at https://ffiec.beta.cfpb.gov/filing/ will remain available on an ongoing basis for filers wishing to test their submissions. Please note that the Beta Platform is for testing purposes only. No data submitted on the Beta Platform will be considered for compliance with HMDA data reporting requirements. To officially submit your HMDA Data for 2023, visit the live HMDA Platform at https://ffiec.cfpb.gov/filing/.

HMDA Platform Tools provide institutions with assistance in creating their HMDA LAR file.  The Online LAR Formatting Tool helps financial institutions, typically those with small volumes of covered loans and applications, create an electronic file that can be submitted to the HMDA Platform. Filers can create their transmittal sheet and LAR rows, entering values for each data field, and use this tool to download the entire LAR file. Filers can also easily edit an existing file by uploading their file to the tool. The Online LAR Formatting Tool does not save any user data.