Attorney Published Article
Navigating the FCRA in the heavy wake and possible undertow of the CARES Act changes to the FCRA
Joseph Apatov (Fort Lauderdale) and Gregg Stevens (Dallas) co-authored an article addressing the CARES Act amendment to the Fair Credit Reporting Act (FCRA) in Westlaw’s Consumer Financial Service Law Report.
The amendment adds Section 1681-s(2)(a)(1)(F): a temporary reporting requirement for furnishers of credit information concerning consumers affected by COVID-19. See Section 4021 of the CARES Act.
Due to its placement in the CARES Act as the section immediately preceding similar sections concerning foreclosures, evictions, and mortgage forbearance, it appears some have misinterpreted the scope of Section 4021 as limited to mortgage loans. However, this is a mistake because Section 4021 has no such limitation, it is applicable to all furnishers.
Read the full article here: “Navigating the FCRA in the heavy wake and possible undertow of the CARES Act changes to the FCRA.”