Credit Reporting and COVID-19: Guidance for Consumer Financial Service Companies Reporting Consumer Credit During and Post Pandemic (On-Demand)

General Credits:


Course Description

Experienced Troutman Pepper attorneys will take a close look at the nitty-gritty of the practical side of credit reporting during the COVID-19 pandemic and economic downturn. We will cover:

  • Brief refresher on the CARES Act amendment to the FCRA, and the regulatory and litigation context
  • A deep dive on implementing CARES Act requirements, using
      • CFPB Policy Statements and FAQs on Credit Reporting
      • Metro 2 standards for credit reporting
      • CDIA Guidance for CARES Act
  • State Law Considerations
      • What happens after the CARES Act expires?


  • The “CARES” Act
  • Amendment to the FCRA
  • CFPB Policy Statements on Credit Reporting
  • CDIA Guidance for CARES Act
  • CDIA Guidance for Forbearance & Natural Disaster Credit Reporting
  • Bankruptcy Reporting & Considerations
  • Key State Actions on Credit Reporting


  1. Amendment to the Fair Credit Reporting Act
  2. New FCRA Provisions
  3. New FCRA Requirements
  4. CFPB Policy Statement on Credit Reporting
  5. CFPB on the CARES Act requirements
  6. CFPB Response to Policy Statement
  7. CFPB FAQs 1-3: General Principles
  8. CFPB FAQs 4-5: Defining “Accommodations”
  9. Key Metro 2 Concepts for FAQs 6-10
  10. CFPB FAQs 6-10: Specific Reporting Guidance
  11. State Law Considerations
  12. FCRA Preemption Provision on Furnishers
  13. COVID-19 State Laws Related To Credit Reporting
  14. How State Laws Impact Compliance Decisions


David Anthony, Esq.

Cindy Hanson, Esq.

Timothy J. St. George, Esq.

Credit Details

Course Type

Course Instructor

Cindy Hanson, Esq., David Anthony, Esq., Timothy J. St. George, Esq.

Original Date Of Course

General Credits