ICBA expressed support for a Consumer Financial Protection Bureau proposed rule that would prohibit consumer reporting agencies from reporting adverse information on victims of human trafficking.
Comment Letter: ICBA said:
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Adverse information and fraudulent activity derived from these crimes should not be transmitted because they do not portray an accurate picture of consumers’ creditworthiness.
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Transmitting adverse information would extend the harm to victims of human trafficking.
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The proposed rule appropriately applies only to credit reporting agencies because they are in the best position to monitor and control that information.
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The CFPB should not expand the proposal to require credit bureaus to inform financial institutions that consumers are human trafficking victims or to require FIs to actively monitor victim status and discern whether adverse information should be reported.