Top-30 Bank is Confident in New Consumer Reporting Disputes Practices

A Hard Look at Internal FCRA Practices

A top-30 bank approached Bridgeforce voicing concerns about how their consumer reporting disputes were being handled. The bank’s internal audit team noticed that they were falling short of their own standards in vendor oversight and monitoring, vendor compliance reporting and timeliness of dispute responses.

To get ahead of this, the bank needed the full picture of their current state of operations. A thorough examination of their processes would identify specific compliance concerns and highlight opportunities for improvement.

The bank sought the support of a firm with deep subject matter expertise in consumer reporting and disputes. So, they called on Bridgeforce, knowing that we had completed over 100 engagements. The bank tasked us with uncovering the compliance risk within their credit reporting disputes operations.

Bridgeforce Brings Deep Subject Matter Expertise in Consumer Reporting and Disputes Practices

Bridgeforce assigned a team of four to assess the full consumer reporting landscape. Combined, the team had more than 56 years of experience working for banks, and another 34 combined years working for Bridgeforce.

We split the project into three distinct phases: assessment, gap/opportunity analysis, and enhancements planning.

In the first phase, the team used our proven assessment methodology to understand the current state of furnishing disputes at the bank for both consumer deposits and home loans. We use proprietary capture matrices for all credit reporting projects. Our matrices, specific to expectations for managing NSCRA and CRA operations, cover both furnishing and disputes.

Consistently, these matrices get us up to speed quickly and leave no stone unturned in our consumer reporting reviews. But that’s only one piece of the puzzle. The Bridgeforce team fully immersed themselves into the client’s work culture to gain an understanding of the client’s operations that couldn’t be found on paper.

Adjusting for Unforeseen Events

The project was touch and go. The bank faced resourcing challenges that forced them to balance this project with other priorities. Sometimes our team was simply waiting on cooperation from a key vendor. But Bridgeforce has been in consumer lending long enough to anticipate occasional delays and was able to take these pauses in stride.

Confidence in the Big Picture: Having a Full and Accurate Fact Pattern to Base Improvements

After 12 months of starting and stopping and starting again, the client had their results. Based on the findings in the assessment phase, we recommended 59 different ways the client could improve their consumer data furnishing and disputes practices.

For instance, we suggested an expansion of their oversight program – which had already been dramatically improved following our audit. Additionally, we gave guidance to enhance their vendor compliance and operational reporting, along with multiple suggestions to improve the accuracy of furnishing and dispute responses.

The client was confident that they had a full and accurate fact pattern for what was going on in their operations.

As the client moves forward to put our recommendations in place, they know that their operations are fully vetted and meeting their own internal standards. The bank also expects noticeable improvements for their customers with stronger investigations on every consumer dispute.

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