FCRA Compliance Management & Risk Mitigation 4

Question 1

Under FCRA Section 611, a CRA may terminate a reinvestigation of a consumer's dispute as 'frivolous or irrelevant' if which condition is met?

Accepted Answer

The consumer fails to provide sufficient information to investigate the dispute

Answer

A CRA may deem a dispute frivolous when the consumer provides insufficient information to conduct a meaningful investigation.

Question 2

A financial institution's compliance management system identifies a pattern of adverse action notices missing the 'right to a free copy of the report' disclosure. Which corrective action addresses BOTH the symptom and root cause?

Accepted Answer

Audit and update the notice template, implement automated template validation, and conduct a lookback to identify consumers who need re-notice

Answer

Fixing the template, adding a technical control to catch future errors, and providing remediation to affected consumers addresses root cause and consumer harm simultaneously.

Question 3

Which FCRA provision specifically governs the obligations of entities that compile and sell lists of consumers for prescreened firm offers of credit or insurance?

Accepted Answer

Section 604(c) — Transactions not initiated by consumers

Answer

Section 604(c) is the FCRA provision that permits prescreened solicitations only when the consumer receives a firm offer and the creditor maintains an opt-out mechanism.

Question 4

An employer wants to conduct a background check on a current employee suspected of workplace theft. Under FCRA, which step is UNIQUE to investigations of current employees versus applicant background checks?

Accepted Answer

The employer may use a consumer report but must provide an 'investigative consumer report' notice describing the nature and scope of the investigation

Answer

For investigative consumer reports used to investigate employee misconduct, FCRA Section 606 requires the employer to disclose the nature and scope of the investigation to the employee.

Question 5

A CRA's compliance team is stress-testing its reinvestigation capacity. Under FCRA, what is the maximum permissible investigation period when a consumer provides additional relevant information during the investigation?

Accepted Answer

45 days when the consumer provides additional information after the initial dispute

Answer

FCRA Section 611(a)(1) allows a 15-day extension (to 45 days total) when the consumer submits additional relevant information during the reinvestigation period.

(FCRA) Advanced Fair Credit Reporting Act Certification Practice Test

(FCRA) Advanced Fair Credit Reporting Act Certification Practice Test

FCRA Compliance Management & Risk Mitigation 4