Consumer Credit Reporting, Credit Bureaus,
June 2, 2020
Credit Scoring, and Related Policy Issues
Cheryl R. Cooper
The consumer data industry—generally referred to as credit reporting agencies or credit
Analyst in Financial
bureaus—collects and subsequently provides information to firms about the behavior of
Economics
consumers when they participate in various financial transactions. Firms use consumer

information to screen for consumer risks. For example, lenders rely upon credit reports
Darryl E. Getter
and scores to determine the likelihood that prospective borrowers will repay their loans.
Specialist in Financial
Insured depository institutions (i.e., banks and credit unions) rely on consumer data
Economics
service providers to determine whether to make available checking accounts or loans to

individuals. Some insurance companies use consumer data to determine what insurance
products to make available and to set policy premiums. Some payday lenders use data

regarding the management of checking accounts and payment of telecommunications and utility bills to determine
the likelihood of failure to repay small-dollar cash advances. Merchants rely on the consumer data industry to
determine whether to approve payment by check or electronic payment card. Employers may use consumer data
information to screen prospective employees to determine the likelihood of fraudulent behavior. In short,
numerous firms rely upon consumer data to identify and evaluate potential risks a consumer may pose before
entering into a financial relationship with that consumer.
Greater reliance by firms on consumer data significantly affects—and potentially limits—consumer access to
financial products or opportunities. Specifically, negative or derogatory information, such as late payments, loan
defaults, and multiple overdrafts, may stay on consumer reports for several years and lead firms to deny a
consumer access to credit, a financial product, or a job opportunity. Having a nonexistent, insufficient, or stale
credit history may also prevent credit access.
Accordingly, various policy issues have been raised about the consumer data industry, most notably including the
following:
 How to address inaccurate or disputed consumer data provided in consumer data reports;
 How long negative or derogatory information should remain in consumer data reports;
 How to address differences in billing and collection practices that can adversely affect consumer
data reports, an issue of particular concern with medical billing practices;
 How to ensure that consumers are aware of their rights and how to exercise them in the event of a
consumer data dispute;
 Whether uses of consumer data reports outside of the financial services, such as for employment
decisions, adversely affect consumers and should be limited;
 Whether the use of alternative consumer data or newer versions of credit scores may increase
accuracy and credit access; and
 How to address data protection and security issues in consumer data reporting.
Congress has shown continuing interest in these and other policy questions surrounding the consumer data
industry. In the 116th Congress, the House passed H.R. 3621, the Comprehensive Credit Reporting Enhancement,
Disclosure, Innovation, and Transparency Act of 2020 (Comprehensive CREDIT Act). This bill includes
legislation from other bills marked up by the House Financial Services Committee: H.R. 3614, H.R. 3618, H.R.
3622, H.R. 3629, H.R. 3642. On March 27, in response to the coronavirus (COVID-19) pandemic, the President
signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act; P.L. 116-136). Section 4021 of the
CARES Act addresses credit reporting during the pandemic. The House also passed the Health and Economic
Recovery Omnibus Emergency Solutions Act (HEROES Act; H.R. 6800). Section 110401 of the bill would create
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Consumer and Credit Reporting, Credit Bureaus, Credit Scoring

a moratorium on furnishing adverse information to credit bureaus during the COVID-19 pandemic period, as well
as for other future major natural disasters.
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Consumer Credit Reporting, Credit Bureaus, Credit Scoring, and Related Policy Issues

Introduction
The consumer data industry collects and subsequently provides information to firms about
behavior when consumers conduct various financial transactions. Firms use this data to determine
whether consumers have engaged in behaviors that could be costly or beneficial to the firms. For
example, lenders rely upon credit reports and scoring systems to determine the likelihood that
prospective borrowers will repay their loans. The data may also be used to predict consumer
behaviors that would financially benefit firms.
Although the general public is likely to be more familiar with the use of credit reporting and
scoring to qualify for mortgage and other consumer loans, the scope of consumer data use is
much broader. Insured depository institutions (i.e., banks and credit unions) rely on consumer
data service providers to determine whether to make checking accounts or loans available to
individuals. Insurance companies use consumer data to determine what insurance products to
make available and to set policy premiums.1 Some payday lenders use data regarding the
management of checking accounts and payment of telecommunications bills to determine the
likelihood that a consumer will fail to repay small-dollar cash advances. Merchants rely on the
consumer data industry to determine whether to approve payment by check or electronic payment
card. Employers may use consumer data information to screen prospective employees to
determine, for example, the likelihood of fraudulent behavior. In short, numerous firms rely upon
consumer data to identify and evaluate the risks associated with entering into financial
relationships or transactions with consumers.
Reliance by firms on consumer data significantly affects consumer access to financial products or
opportunities. For example, negative or derogatory information, such as multiple overdrafts,
involuntary account closures, loan defaults, and fraud incidents, may influence a lender to deny a
consumer access to credit. Further, such information may stay on a consumer’s reports for several
years. The inclusion of negative information may be particularly limiting to consumers under
circumstances in which such information is inaccurate or needs to be updated to reflect more
current and possibly more favorable financial situations. Furthermore, consumers may find the
process of making corrections to consumer data reports to be time-consuming, complex, and
perhaps ineffective. The exclusion of more favorable information, such as the timely repayment
of noncredit obligations, from standard credit reporting or scoring models may also limit credit
access.
This report first provides background information on the consumer data industry and various
specialty areas. The report examines one prominent specialty area—consumer scoring—and
describes various factors used to calculate credit scores. Next, the report provides a general
description of the current regulatory framework of the consumer data industry. Finally, the report
discusses selected policy issues pertaining to consumer data reports. Specifically, the report
addresses policy issues concerning (1) inaccurate or disputed consumer data provided in
consumer data reports; (2) how long negative or derogatory information should remain in
consumer data reports; (3) differences in billing and collection practices that can adversely affect
consumer data reports, an issue of particular concern with medical billing practices; (4)
consumers’ rights; (5) whether uses of credit bureau data outside of the financial services, such as
for employment decisions, adversely affect consumers and should be limited; (6) whether the use
of alternative consumer data or newer versions of credit scores may increase accuracy and credit

1 See CRS Report RS21341, Credit Scores: Credit-Based Insurance Scores, by Baird Webel.
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access; and (7) how to address data protection and security issues in consumer data reporting. For
each policy issue, the report addresses corresponding legislative and regulatory developments.
In the 116th Congress, credit reporting and the consumer data industry is a topic of interest.2 On
January 29, 2020, the House passed H.R. 3621, the Comprehensive Credit Reporting
Enhancement, Disclosure, Innovation, and Transparency Act of 2020 (Comprehensive CREDIT
Act). This legislation includes other bills marked up and ordered reported by the House Financial
Services Committee: H.R. 3614 (The Restricting Credit Checks for Employment Decisions Act,
Title VI of bill); H.R. 3618 (The Free Credit Scores for Consumers Act of 2019, Title II of bill);
H.R. 3622 (Restoring Unfairly Impaired Credit and Protection Consumers Act, Title IV of bill);
H.R. 3629 (The Clarity in Credit Score Formation Act of 2019, Title V of bill); and H.R. 3642
(The Improving Credit Reporting for All Consumers Act, Title I and VII of the bill). Where
relevant, this report discusses the approach this bill would take to address the policy issues
examined.
COVID-19 Pandemic and Credit Reporting
On March 27, in response to the coronavirus (COVID-19) pandemic, the President signed the Coronavirus Aid,
Relief, and Economic Security Act (CARES Act; P.L. 116-136). Section 4021 of the CARES Act addresses credit
reporting during the pandemic. It requires furnishers during the COVID-19 pandemic covered period to report to
the credit bureaus that consumers are current on their credit obligations if they enter into an agreement to defer,
forbear, modify, make partial payments, or get any other assistance on their loan payments from a financial
institution and fulfil those requirements, provided they were current before this period.3
Although the CARES Act protects the credit histories of consumers with forbearance agreements, some
consumers may stil experience harm to their credit record because lenders can choose whether to enter into an
assistance agreement for many types of consumer loans. On May 15, 2020, the House passed the Health and
Economic Recovery Omnibus Emergency Solutions Act (HEROES Act; H.R. 6800). Section 110401 of the bil
would address this by creating a moratorium on furnishing adverse information to credit bureaus during the
COVID-19 pandemic and for 120 days afterward, as well as for other future major natural disasters. Although
these provisions would protect consumers from lower credit scores, the removal of information may also reduce
credit scores’ predictability in the future, which could harm some consumers in the long term. For more
information on credit reporting, the COVID-19 pandemic, and the CARES Act, see the Appendix.
The Consumer Data Industry and Specialty Services
This section provides background information on the consumer data industry, which generally
includes credit reporting agencies (CRAs), also referred to as credit bureaus (both terms are used
interchangeably in this report). This section also provides background on credit scoring, a

2 On February 26, 2019, the House Financial Services Committee held a hearing on the consumer data industry; see
U.S. Congress, House Committee on Financial Services, “Who’s Keeping Score? Holding Credit Bureaus Accountable
and Repairing a Broken System,” 116th Cong., February 26, 2019. The Senate has also expressed interest in credit
reporting and the consumer data industry; see U.S. Congress, Senate Committee on Banking, Housing, and Urban
Affairs, “Crapo Outlines Banking Committee Agenda for 116th Congress,” prepared by Chairman Mike Crapo, 116th
Cong., 1st sess., January 29, 2019, at https://www.banking.senate.gov/newsroom/majority/crapo-outlines-agenda-for-
116th-congress.
3 If the consumer was delinquent before the covered period, then the furnisher should maintain the delinquent status
unless the consumer brings the account or obligation current. The covered period starts on January 31, 2020, and
extends to the later of 120 days after enactment or 120 days after the national emergency declared by the President on
March 13, 2020, terminates. For more information, see CFPB, Statement on Supervisory and Enforcement Practices
Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act, April 1, 2020, at
https://files.consumerfinance.gov/f/documents/cfpb_credit-reporting-policy-statement_cares-act_2020-04.pdf.
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specialty service the industry provides, including a summary of the key factors known to affect
credit scores.
Consumer Reporting Services
According to the Fair Credit Reporting Act (FCRA), which generally regulates the business of
credit reporting, CRAs are firms that prepare consumer reports based upon individuals’ financial
transactions history data.4 Such data may include historical information about credit repayment,
tenant payment, employment, insurance claims, arrests, bankruptcies, and check writing and
account management. Consumer files, however, do not contain information on consumer income
or assets.5 Consumer reports generally may not include information on items such as race or
ethnicity, religious or political preference, or medical history.6
Equifax, Experian, and TransUnion are the three largest nationwide providers of credit reports.7
Other CRAs provide a variety of specialized consumer reporting services.8 Some specialty CRAs
collect data regarding payment for phone, utilities (e.g., electric, gas, water), and
telecommunication (e.g., cable) services.9 Utility and telecommunication service providers use
the reports to verify the identity of customers and determine downpayment requirements for new
customers. Property management companies and rent payment services may report to CRAs that
specialize in collecting rent payment data for tenant and employment screening.10 Some CRAs
specialize in consumer reporting for the underbanked, near prime, and subprime consumer
segments, including consumers with minimal recorded data.11 Some CRAs specialize in debt
collection (recovering past due funds) and fraud verification data.12

4 P.L. 91-508. Title VI, §601, 84 Stat. 1128 (1970), codified as amended at 15 U.S.C. §§1681-1681x. For the legal
definition, see 12 C.F.R. §1090.104, “Consumer Reporting Market,” at http://www.ecfr.gov/cgi-bin/text-idx?SID=
c13cb74ad55c0e8d6abf8d2d1b26a2bc&mc=true&node=se12.9.1090_1104&rgn=div8. The Fair Credit Reporting Act,
the Fair Debt Collection Practices Act, and the Equal Credit Opportunity Act are all consumer credit protection
amendments included in the Consumer Credit Protection Act (P.L. 90-321).
5 See Bureau of Consumer Financial Protection (CFPB), Key Dimensions and Processes in the U.S. Credit Reporting
System, December 2012, at http://files.consumerfinance.gov/f/201212_cfpb_credit-reporting-white-paper.pdf.
6 See Federal Reserve Board (FRB), “Federal Fair Lending Regulations and Statutes: Equal Credit Opportunity
(Regulation B),” Consumer Compliance Handbook, at http://www.federalreserve.gov/boarddocs/supmanual/cch/
fair_lend_reg_b.pdf; and Experian, “Basic Questions About Credit Reports and Credit Reporting,” Reports on Credit
issue 1, at https://www.experian.com/assets/consumer-education-content/brochures/Reports_Issue_1.pdf.
7 For a list of consumer reporting agencies, see “List of Consumer Reporting Agencies,” issued by CFPB, at
https://files.consumerfinance.gov/f/documents/cfpb_consumer-reporting-companies-list.pdf
8 Some specialty CRAs are subsidiaries of larger CRAs. Examples include the National Consumer Telecom & Utilities
Exchange, at http://www.nctue.com/, which is owned by Equifax; and RentBureau, at http://www.experian.com/
rentbureau/renter-credit.html, which is owned by Experian.
9 For example, see National Consumer Telecom & Utilities Exchange, at http://www.nctue.com/.
10 For example, see Experian RentBureau, at http://www.experian.com/rentbureau/renter-credit.html.
11 For example, see Clarity Services, Inc., at https://www.clarityservices.com/about/, which focuses on higher-risk
borrowers and collects data from financial service providers, such as auto financers, check cashers, prepaid card
issuers, peer-to-peer micro lenders, and small dollar credit lenders.
12 See Consumer Data Industry Association (CDIA), “About CDIA,” at https://www.cdiaonline.org/about/index.cfm?
unItemNumber=515.
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Examples of Specialty CRA Services: Checking Accounts and Check Verification
When an individual applies for a checking account, a depository institution typically pays a fee to purchase a credit
report from a specialty CRA. This is a component of the initial fixed costs the depository institution incurs to
begin a financial relationship with a new customer. The institution can use the information about a prospective
customer to determine whether to offer the consumer a checking account and, if so, what range of product
features (e.g., check-writing privileges, overdraft protection) to offer the consumer.
Specifically, depository institutions use credit reports to screen for certain types of borrower risks.13 Banks must
verify the identities of their customers as required by the Bank Secrecy Act.14 In addition, depository institutions
look for any incidents of fraudulent activity associated with a prospective customer.15 Depository institutions
typically reject consumers when they discover problems verifying identity or incidents of fraud. Next, depository
institutions look for information about past banking relationships, particularly to see if any financial institutions
closed checking or other accounts due to their inability to col ect overdraft or insufficient funds fees.16 Although
some institutions may choose to reject applicants if they discover adverse information in their credit reports,
many institutions may offer these applicants specialized checking accounts with less overdraft coverage and fewer
check-writing privileges. Institutions may also offer these applicants prepaid cards as a substitute for a checking
account. The information the institutions obtain from CRAs may also allow them to infer the probability of cross-
selling (or arguably preapproving access to) other financial products (e.g., mortgages, credit cards, savings
accounts) to new customers.
Some specialty CRAs help facilitate consumer payments by check. For example, if a customer wants to use a check
to pay for purchases, a merchant can electronically and quickly request check authorization from a specialty CRA
that provides information at the point of sale (at the cash register).17 The specialty CRA col ects payment history
and check-writing patterns, and the merchant pays a check authorization fee to obtain an instant recommendation
of accept or decline.18
Firms that use consumer reports may also report information to CRAs, thus serving as furnishers.
A tradeline is an account attached to a particular consumer that is reported to a CRA by a
furnisher.19 A tradeline serves as a record of the transaction (payment) activity associated with the
account. Furnishing tradelines is voluntary, and furnishers are not required to submit tradelines to
all CRAs. Furnishers also have different business models and policies, resulting in different

13 See ChexSystems, “ChexSystems—Credit System for Checking Accounts,” Crediful, at https://www.crediful.com/
chexsystems/.
14 P.L. 91-508.
15 Fraud may include, but is not limited to, identity theft and check kiting. Real Time Identity Check is a specialty CRA
used for this purpose; see Access Payment Systems, “Real Time Check Verification,” at
http://www.accesspaymentsystems.com/real-time-check-verification/. Another specialty CRA used for this purpose is
Early Warning, which offers a product known as Deposit Chek, at https://www.earlywarning.com/solutions/payment/
deposit-chek.html#real-time-deposit-chek-service. In the payment system, fraud occurs when an unauthorized person
accesses the value associated with a payment vehicle. See Mark Furletti and Stephen Smith, The Laws, Regulations,
and Industry Practices That Protect Consumers Who Use Electronic Payment Systems: ACH E-Checks & Prepaid
Cards, Federal Reserve Bank of Philadelphia, Payment Cards Center Discussion Paper, DP05-04, March 2005, at
http://www.philadelphiafed.org/consumer-credit-and-payments/payment-cards-center/publications/discussion-papers/
2005/ConsumerProtection.pdf.
16 For ChexSystems, which is owned by parent company Fidelity National Information Services (FNIS), this product is
known as QualiFile. See Rebecca Lake, “What Is a Good ChexSystems (Qualifile) Score?” My BankTracker, July 20,
2018, at https://www.mybanktracker.com/checking/faq/good-chexsystems-qualifile-score-276348. For Early Warning,
this product is known as Deposit Chek at https://www.earlywarning.com/solutions/payment/deposit-chek.html#real-
time-deposit-chek-service.
17 Certegy, which is owned by parent company FIS (see http://www.fisglobal.com/products-retailpayments), and
Telecheck (see http://www.firstdata.com/telecheck/) are specialty CRAs often used to obtain check authorization at the
point of sale (i.e., the moment customers pay for their purchases).
18 The fee paid by the merchant is analogous to the merchant discount fee that merchants pay when accepting credit or
debit card payments. See CRS Report R41913, Regulation of Debit Interchange Fees, by Darryl E. Getter.
19 See Experian, “Glossary of Credit Terms,” at http://www.experian.com/credit-education/glossary.html.
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reporting practices. Some furnishers may report all unpaid customer obligations that were deemed
uncollectible and written off their balance sheets; some report when money balances owed
surpass minimum threshold levels; some report only the principal balances owed minus the
penalties and fees; and others may report all monies owed. Furnishers also have discretion over
the types of obligations they wish to report.20
Benefits to users of consumer data increase as more individual companies choose to participate as
furnishers, but furnishers do incur costs to report data. To become furnishers, firms must be
approved and comply with the policies of a CRA, such as fee registration requirements.21 The
transfer of consumer data involves security risks, and many CRAs have adopted standardized
reporting formats and requirements approved by the Consumer Data Industry Association (CDIA)
for transferring data.22 Furnishers must be able to comply with industry data transfer requirements
or some CRAs are unlikely to accept their data. Compliance may require investing in technology
compatible with the computer systems of a CRA. Compliance costs may be more burdensome for
smaller firms, causing some to choose not to be furnishers. In addition, entities that elect to
become furnishers face legal obligations under the FCRA.23 The FCRA requires furnishers to
report accurate and complete information as well as to investigate consumer disputes. Hence,
reporting obligations could possibly, under some circumstances, result in legal costs, which may
also influence a firm’s decision to become a furnisher.
Business models and policies of CRAs are also different. Different CRAs may collect the same
information on the same individuals but adopt different conventions for storing the information.
One CRA may report a delinquent debt obligation separately from the penalties and fees whereas
another CRA may choose to combine both items into one entry. Consequently, consumer reports
obtained from different CRAs on the same consumer are likely to differ due to different policies
adopted by furnishers, CRAs, or both.
Credit Scoring Services
A consumer score is a (numeric) metric that can be used to predict a variety of financial
behaviors.24 Consumer credit scores are prepared for lenders to determine, for example, the
likelihood of loan default. Other consumer scores can be prepared to predict the likelihood of
filing an insurance claim, overdrawing a bank account, failing to pay a utility bill, committing
fraud, or a host of other adverse financial behaviors. Consumer scores are typically computed
using the information obtained from one or more consumer reports. Rather than maintaining a
repository of credit records, some firms are primarily engaged in the production of consumer

20 A community bank, for example, may choose to report delinquencies on consumer loans rather than on commercial
loans given that it may have greater information regarding the cash flow circumstances of its larger commercial
borrowers. See Federal Trade Commission (FTC) and FRB, Report to Congress on the Fair Credit Reporting Act
Dispute Process, August 2006, at http://www.federalreserve.gov/boarddocs/rptcongress/fcradispute/
fcradispute200608.htm#toc4.
21 For examples of some furnisher requirements, see Experian, “Reporting to Credit Agencies,” at
http://www.experian.com/consumer-information/reporting-to-credit-agencies.html.
22 The approved formats add security (privacy) protections to the data transfer process. See CDIA, “Metro 2 Format for
Credit Reporting,” at https://www.cdiaonline.org/resources/furnishers-of-data-overview/metro2-information/.
23 See FTC, “Consumer Reports: What Information Furnishers Need to Know,” at https://www.ftc.gov/tips-advice/
business-center/guidance/consumer-reports-what-information-furnishers-need-know.
24 The predictability power of consumer scores, assuming no significant changes in consumer repayment patterns, may
last for approximately one year to two years. For examples of various types of scores and corresponding estimated
months of predictive power, see TransUnion, “Scores Overview,” TransUnion Scores, at http://www.transunion.com/
docs/financialServices/FS_ScoresOverview.pdf.
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scores.25 Hence, consumer scoring can be considered a specialty service in the consumer data
industry. For example, if a user of a consumer report subsequently wants a consumer score, it
may be charged an additional fee.
Given the variety of different financial behaviors to predict, there are many consumer scores that
can be calculated. Consumer scores for the same individual and behavior calculated by different
scoring firms are also likely to differ. Consumer scoring firms may have purchased consumer
information from different CRAs, which have their own policies for storing and reporting
information. Each scoring firm has its own proprietary statistical model(s), meaning that each
firm decides what consumer information should be included and excluded from calculations.
Each firm can choose its own weighting algorithms. For example, included information can be
equally weighted, or heavier weights can be placed on more recent information or on information
otherwise deemed more pertinent. Sometimes the consumer scoring firm selects the appropriate
weighting scheme, and sometimes the requestor of a consumer score may provide instructions to
the preparer. Hence, consumers may not see the actual scores used until after the decisionmaking
firms release them, particularly in cases when customized scores were requested and used in the
decisionmaking process.

25 FICO (see http://www.fico.com/en/) and VantageScore (see http://www.vantagescore.com/) are examples of firms
that specialize in the production of credit scores; their primary business is not to compile consumer reports.
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Some Factors Frequently Used to Calculate Credit Scores26
Lenders, whether for mortgages or other forms of consumer loans (e.g., credit card loans, installment loans, and
automobile loans), rely upon credit scores, which are calculated to represent the risk of delinquency or default of
consumers seeking credit. To calculate a credit score, credit scoring models generally obtain the fol owing factors
from a credit report.

Payment history. A lender is concerned about the borrower paying past credit accounts on time. The
payment history includes information related to late or missed payments, how late, how much was owed,
bankruptcies, foreclosures, lawsuits, and wage garnishments. Negative information on a credit report
negatively affects a credit score.

Credit utilization. This factor provides information regarding the amount of outstanding debt a consumer
has accumulated relative to his or her credit limit. An individual with $3,000 in charges on a credit card with
a $5,000 limit would have a credit utilization rate of 60%. A high credit utilization rate negatively affects a
credit score.

Length of credit history. The more experience an individual has using credit, the easier it is for a lender to
determine how well or poorly additional credit wil be managed. Calculating credit scores may be impossible
for “invisible” consumers (i.e., consumers with either no credit history or an insufficient credit history).

New credit accounts or requests. There are two types of inquiries. A soft inquiry occurs when
consumers request to check their credit reports, typically for accuracies or to dispute information, but there
is no corresponding request for credit. Users of credit reports do not receive information regarding soft
inquiries. A hard inquiry occurs when consumers apply for credit, and action is required by users of credit
reports, typically to make approval or rejection decisions. Hence, making numerous different credit requests,
particularly over a short period of time, generally can negatively affect a score. If a consumer shops for credit,
which would be indicated by applying for the same type of credit within a short period of time (e.g., two to
six weeks), then that activity would count only as one hard inquiry in most credit scores.27 Prescreening,
which is used frequently in credit card solicitations, does not count as a “firm offer of credit or insurance”
and, therefore, does not affect consumer credit scores.28

Credit mix. Demonstrating the ability to manage multiple types of credit obligations (i.e., revolving,
installment, mortgage credit, and finance company credit) influences a credit score. For example, the ability to
maintain a stable debt-to-income ratio, preferably below 28%, despite having a mix of credit types, indicates
the ability to manage credit. Having most of one’s credit consist of credit from indirect lenders, such as
department stores and rent-to-own stores, may not be viewed as favorably in some credit scoring models as
credit from direct lenders, such as banks and credit unions.
The firm that prepares or user that purchases a credit score can decide how much weight to apply to each factor,
and they may include additional predictive factors (e.g., information found on the credit application such as income
and employment history) in the calculations. The Equal Credit Opportunity Act, however, prohibits characteristics
such as race, sex, marital status, national origin, and religion from being used in credit scoring models.29
Information for consumers on how to improve and maintain a good credit score is available from the Consumer
Financial Protection Bureau (see https://www.consumerfinance.gov/consumer-tools/credit-reports-and-scores/).
Existing Consumer Protections and Regulation
of CRAs
This section provides a brief overview of existing consumer protections and regulation related to
credit reporting.

26 See Fair Isaac, “What’s In My FICO Scores: How My FICO Scores Are Calculated,” at http://www.myfico.com/
crediteducation/whatsinyourscore.aspx; and FRB, “Credit Reports and Credit Score,” at
https://www.federalreserveconsumerhelp.gov/learnmore/credit-reports-and-scores?sc_lang=en.
27 CFPB, What effect will shopping for an auto loan have on my credit? Ask CFPB, June 6, 2016, at
https://www.consumerfinance.gov/ask-cfpb/what-effect-will-shopping-for-an-auto-loan-have-on-my-credit-en-763/.
28 See FRB, “Permissible Purposes of Consumer Reports (FRCA, Section 604) and Investigative Consumer Reports
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As noted, the Fair Credit Reporting Act (FCRA), enacted in 1970, is the main statute regulating
the credit reporting industry. The FCRA requires “that consumer reporting agencies adopt
reasonable procedures for meeting the needs of commerce for consumer credit, personnel,
insurance, and other information in a manner which is fair and equitable to the consumer, with
regard to the confidentiality, accuracy, relevancy, and proper utilization of such information.”30
The FCRA establishes consumers’ rights in relation to their credit reports, as well as permissible
uses of credit reports. It also imposes certain responsibilities on those who collect, furnish, and
use the information contained in consumers’ credit reports.31
The FCRA includes consumer protection provisions. Under the FCRA, consumers must be told
when their information from a CRA has been used after an adverse action (generally a denial of
credit) has occurred, and disclosure of that information must be made free of charge.32 Consumers
have a right to one free credit report every year (from each of the three largest nationwide credit
reporting providers) even in the absence of an adverse action (e.g., credit denial). Consumers also
have the right to dispute inaccurate or incomplete information in their report. After a consumer
alerts a CRA of such a discrepancy, the CRA must investigate and correct errors, usually within
30 days. The FCRA also limits the length of time negative information may remain on reports.
Negative collection tradelines typically stay on credit reports for 7 years, even if the consumer
pays in full the item in collection; a tradeline associated with a personal bankruptcy stays on a
credit report for 10 years.33
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank)34 established
the Bureau of Consumer Financial Protection (CFPB), consolidating many federal consumer
financial protection powers from other federal agencies. The CFPB has rulemaking and
enforcement authorities over all CRAs for certain consumer protection laws; it has supervisory
authority, or the authority to conduct examinations, over the larger CRAs. In July 2012, the CFPB
announced that it would supervise CRAs with $7 million or more in annual receipts, which
included 30 firms representing approximately 94% of the market.35
The CFPB conducts examinations of the CRAs, reviewing procedures and operating systems
regarding the management of consumer data and enforcing applicable laws. In 2017, the CFPB
released a report of its supervisory work in the credit reporting system.36 The report discusses the
CFPB’s efforts to work with credit bureaus and financial firms to improve credit reporting in

(FRCA, Section 606),” Fair Credit Reporting, at http://www.federalreserve.gov/boarddocs/supmanual/cch/200611/
fcra.pdf; CFPB, Key Dimensions and Processes in the U.S. Credit Reporting System, December 2012, p. 9, at
http://files.consumerfinance.gov/f/201212_cfpb_credit-reporting-white-paper.pdf; and “New Rules for Prescreening,”
at https://www.bankersonline.com/articles/103643.
29 P.L. 93-495, Title 5, 88 Stat. 1520; 15 U.S.C. §1691 et seq.
30 15 U.S.C. §1681.
31 CRS Insight IN10792, The Equifax Data Breach: An Overview and Issues for Congress, by N. Eric Weiss.
32 See FTC, A Summary of your Rights Under the Fair Credit Reporting Act, at https://www.consumer.ftc.gov/articles/
pdf-0096-fair-credit-reporting-act.pdf.
33 CFPB, How long does negative information remain on my credit report? Ask CFPB, August 4, 2016, at
https://www.consumerfinance.gov/ask-cfpb/how-long-does-negative-information-remain-on-my-credit-report-en-323/.
34 P.L. 111-203, §1011.
35 CFPB, “CFPB to Supervise Credit Reporting,” July 16, 2012, at http://www.consumerfinance.gov/newsroom/
consumer-financial-protection-bureau-to-superivse-credit-reporting/.
36 CFPB, Supervisory Highlights Consumer Reporting Special Edition, Issue 14, 2017, at
https://files.consumerfinance.gov/f/documents/201703_cfpb_Supervisory-Highlights-Consumer-Reporting-Special-
Edition.pdf.
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three specific areas: data accuracy, dispute handling and resolution, and furnisher reporting. As
the report describes, credit bureaus and financial firms have developed data governance and
quality control programs to monitor data accuracy through working with the CFPB. In addition,
the CFPB has encouraged credit bureaus to improve their dispute and resolution processes,
including making it easier and more informative for consumers.37
Recently, Congress has also been interested in improving consumer protections in the credit
reporting system, particularly in response to the 2017 Equifax data breach, which exposed
personal information of millions of consumers.38 The 2018 Economic Growth, Regulatory Relief,
and Consumer Protection Act (P.L. 115-174) established new consumer protections relating to
credit reporting, including the right to a free credit freeze. Credit freezes allow consumers to stop
new credit from being opened in their name, to protect themselves from fraud and identity theft.
Policy Issues
This section examines selected policy issues pertaining to the use of credit reports and scores in
consumer lending decisions. For each policy issue, the report highlights recent legislative and
regulatory developments and discusses selected legislative proposals from the 116th Congress that
would address the issue.
Inaccurate or Disputed Information
The accuracy of consumer information in consumer data reports has been an ongoing policy
concern. Inaccurate information in a credit report may limit a consumer’s access to credit in some
cases or increase the costs to the consumer of obtaining credit in others. In 2012, the Federal
Trade Commission (FTC) reported that 26% of participants in a survey of credit report accuracy
were able to identify at least one potentially material error on at least one of approximately three
different credit reports prepared using their consumer information.39 After the reports were
corrected, 13% of participants in the FTC study saw one or more of their credit scores increase.
For those who saw an increase, over 40% of their scores rose by more than 20 points, which
could increase the likelihood that the consumer would be offered less expensive credit terms.
Credit reporting inaccuracies may occur for various reasons. Consumers may inadvertently
provide inaccurate data when applying for financial services. Furnishers may inadvertently input
inaccurate information into their databases. Matching information to the proper individual poses
challenges, such as in cases when multiple individuals have similar names and spellings. In some
cases, the information may be properly matched, but the individual could be a victim of fraud or
identity theft.

37 The credit bureaus’ efforts to make disputes easier and more informative for consumers include (1) online portals to
submit disputes and upload attachments of supporting documentation; (2) improvements to their call center scripts and
training regarding solicitation of relevant information from consumers with disputes; (3) no longer requiring that
consumers obtain or purchase a recent consumer report before investigations; and (4) notice to consumer of dispute
results, including investigation results. CFPB, Supervisory Highlights Consumer Reporting Special Edition, Issue 14,
2017, pp.9-11, at https://files.consumerfinance.gov/f/documents/201703_cfpb_Supervisory-Highlights-Consumer-
Reporting-Special-Edition.pdf.
38 Equifax, “Equifax Announces Cybersecurity Incident Involving Consumer Information,” press release, September 7,
2017, at https://investor.equifax.com/news-and-events/news/2017/09-07-2017-213000628.
39 See FTC, Report to Congress Under Section 319 of the Fair and Accurate Credit Transactions Act of 2003,
December 2012, at https://www.ftc.gov/sites/default/files/documents/reports/section-319-fair-and-accurate-credit-
transactions-act-2003-fifth-interim-federal-trade-commission/130211factareport.pdf.
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The predictive power of consumer data, or the ability to accurately predict a consumer’s
likelihood to default on a loan, would be enhanced to the extent that consumer tradelines are
regularly updated with correct and current information. As mentioned in the previous section, the
CFPB has recently encouraged credit bureaus and financial firms to improve data accuracy in
credit reporting. For example, since 2014, the CFPB has required the largest consumer reporting
firms to provide standardized accuracy reports on a regular basis.40 The accuracy reports must
specify the frequency that consumers dispute information, list furnishers and industries with the
most disputes, and provide dispute resolution information. According to the CFPB, the top 100
furnishers provide 76% of tradeline information to the largest nationwide CRAs, and the
furnishers regularly update the account status of reported tradelines.41 In addition, the larger
CRAs have also made improvements to the communication tool they use to facilitate the dispute
resolution process between consumers and furnishers.42 Further, effective July 1, 2017, the CRAs
enhanced public record data standards for the collection and timely updating of civil judgements
and tax liens.43 Public record data must contain minimum identifying information (i.e., name,
address, and Social Security number or date of birth) and must be updated at least every 90 days;
otherwise, the tax lien and civil judgment information will no longer be reported. The accuracy of
credit reports, nonetheless, ultimately depends upon consumers to monitor and dispute any
discrepancies.
H.R. 3621 would address some concerns relating to inaccurate or disputed data by establishing
new consumer rights around the dispute process. The bill would guarantee consumers more
information about dispute investigations and would grant consumers the right to appeal disputes
to credit bureaus, thus formalizing the process.44 It also would explicitly establish consumers’
right to seek injunctive relief, a legal remedy where a court requires future behavior change (e.g.,
removing adverse information from a credit record).45 Moreover, it would provide credit
restoration to consumers who are the victims of some predatory activities, such as deceptive
lender acts or fraud.46
Length of Time to Retain Negative Information
Policymakers have also considered the appropriate length of time negative information should be
allowed to remain on a credit report. Negative information generally refers to delinquencies or
defaults, which typically remain on credit reports for seven years. Negative information in a
credit report often results in a consumer appearing to pose a greater risk of default or other
negative behavior. This may lead a consumer to either pay more for financial services or, in some

40 See CFPB, “Prepared Remarks of CFPB Director Richard Cordray at the Medical Debt Collection Hearing,”
December 11, 2014, at http://www.consumerfinance.gov/newsroom/prepared-remarks-of-cfpb-director-richard-
cordray-at-the-medical-debt-collection-hearing/. A sample accuracy report may be found at
http://files.consumerfinance.gov/f/201412_cfpb_sample-accuracy-report.pdf.
41 See CFPB, Key Dimensions and Processes in the U.S. Credit Reporting System, December 2012, p. 14, at
http://files.consumerfinance.gov/f/201212_cfpb_credit-reporting-white-paper.pdf.
42 The CRAs use a web-based tool, the Online Solution for Complete and Accurate Reporting (e-OSCAR), to
investigate credit reporting disputes. e-OSCAR is owned and operated by four companies: Equifax, Experian, Innovis,
and TransUnion. See http://www.e-oscar.org/.
43 See Consumer Data Industry Association, “New Public Record Credit Reporting Standards to Begin July 1, 2017;
Civil Judgments and some Tax Liens to be removed from many credit reports,” press release, June 28, 2017, at
http://s3.amazonaws.com/rdcms-cdia/files/production/public/PDFs/CDIA.NCAP.July1Changes.6.28.pdf.
44 Title I of H.R. 3621.
45 §110 of H.R. 3621.
46 Title IV H.R. 3621.
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cases, be denied access to credit entirely. Limiting a consumer’s access to certain financial
services, such as depository checking accounts or lower cost loans, may disproportionately affect
the consumer’s cost of engaging in financial transactions. Similarly, the use of consumer data
reports by potential employers, discussed below, may limit job opportunities that could arguably
help applicants overcome financial challenges and thereby improve their credit histories.47
Retaining negative information on credit reports for an extended period of time may pose benefits
and detriments. On the one hand, under circumstances in which the underlying information in a
consumer data report is inaccurate or out of date, consumers may improperly be considered to
pose a greater risk to a firm. In that case, the consumer may be offered costlier credit options (or
even face denials of credit) that do not accurately reflect the consumer’s actual risk of default. In
other cases, consumers also may unfairly be considered to pose a greater risk now due to
circumstances in the past that they have since overcome. On the other hand, the longer
information remains on the credit report arguably allows lenders to see long-term trends that may
be helpful for distinguishing between a rare occurrence and a consistent pattern in a consumer’s
behavior. Shorter or insufficient periods of time in which negative tradelines appear on consumer
reports may also compromise the ability to compute reliable scores. If lenders view credit reports
and scores as unreliable due to premature removal of negative information, they could increase
downpayment requirements across the board for all credit applicants or reduce loan amounts. In
short, lenders who are uncertain about data reliability might adopt stricter underwriting and
lending policies. In addition to restricting credit access generally, this could reduce competition
by allowing lenders with an established relationship and more information on a consumer to
provide more favorable terms to that consumer than other companies. In addition, the Association
of Certified Fraud Examiners (ACFE) found that poor credit can signal criminal activity, and
earlier removal of negative information may make it more difficult for an organization to detect
fraud, which may be particularly costly for small businesses and nonprofit organizations.48
Many preparers and users of credit scores have adopted weighting schemes that place less weight
on older information in a consumer data report. Maintaining longer (rather than shorter) durations
of negative tradelines on reports allows preparers to make greater use of variable-weighted
algorithms to calculate scores, which may be useful when the importance of a weight needs to be
modified over time. In addressing this policy issue, H.R. 3621 would shorten the time period that
adverse information could remain on a person’s credit report by three years (such that it remains
on the report for a total of four years), among other things.49

47 See Dana Dratch, “States Weigh Limits on Credit Checks for Employment,” CreditCards.com, at
http://www.creditcards.com/credit-card-news/states-weigh-limits-credit-checks-for-employment-1282.php.
48 See Michelle Long, “Internal Controls for Small Businesses to Reduce the Risk of Fraud,” Intuit, at
http://longforsuccess.com/wp-content/uploads/2010/09/Good-Internal-Controls.pdf; and Association of Certified Fraud
Examiners (ACFE), Report to the Nations on Occupational Fraud and Abuse: 2012 Global Fraud Study, Fraud Q&A
with James Ratley, President and CEO of the ACFE, at https://www.acfe.com/uploadedFiles/ACFE_Website/Content/
rttn/2012-report-to-nations.pdf. Approximately 36% of fraudsters live beyond their means and 27% undergo personal
financial difficulties. See Preventing and Detecting Fraud in Not-For-Profit Organizations, at
https://www.kellerowens.com/wp-content/uploads/2012/07/Fraud-Booklet-2012-Revised-Version.pdf.
49 §401 of H.R. 3621.
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Rehabilitation of Education Loans
Borrowers who default on some federal student loan programs (defined as not having made a payment in more
than 270 days) have a one-time loan rehabilitation option.50 A loan rehabilitation (as opposed to a loan
consolidation) requires a defaulted borrower to make 9 on-time monthly payments during a period of 10
consecutive months.51 The loan is considered rehabilitated if the borrower satisfies the requirements, and then
the loan may be reinstated. In addition, the borrower’s credit report is generally updated to show that the loan is
no longer in default (or the default record would be eliminated); however, the information pertaining to the late
payments that led up to the rehabilitation would stil remain for seven years.52
By contrast, students who default on private loans are less likely to receive a rehabilitation option.53 P.L. 115-174,
Section 602, allows a borrower a one-time opportunity to remove a reported default on a qualified (private)
student loan from a credit report if the borrower satisfies the requirements of loan rehabilitation programs that
private lenders may be wil ing to offer (with the approval of prudential regulators), which is analogous to the
procedures fol owed when federal student loans are in default.54 However, depositories (i.e., banks and credit
unions), which are regulated for safety and soundness, treat their student loans like all other private consumer
loans. Private student loans must stil satisfy underwriting requirements, typically requiring co-signers who become
responsible for the loans if the students are unable to repay. After 120 days past due (closed-end), consumer loans
held by depositories are treated as uncol ectible.55 The Office of the Comptrol er of the Currency also points out:
“Banks have some latitude to offer similar federal workout programs to private student loans. Banks, however,
should do so while adhering to safety and soundness requirements and fol owing existing banking guidance and
GAAP.”56 Apart from safety and soundness requirements, the information pertaining to the late payments that led
up to the rehabilitation would likely remain on the students’ credit reports for seven years even if the default
records were removed. Hence, this information would stil be likely to be incorporated in students’ credit scores.
H.R. 3621 would require credit bureaus to remove adverse information for private student loan borrowers who
have demonstrated a history of repayment, similar to federal student loans.57 Private lenders currently have
discretion in offering rehabilitation; under H.R. 3621, however, all private student loan borrowers would have the
right to obtain loan rehabilitation. This provision would increase the ability of private student loan borrowers to
receive rehabilitation. Because this practice would likely increase costs on financial institutions, as discussed above,
this provision might reduce the wil ingness of lenders to originate private student loans.58
Inconsistent Billing and Reporting Practices: Medical Tradelines
Another policy issue that often arises in connection with credit reporting is that different holders
of consumer debt bill differently and report to the CRAs differently. Inconsistent reporting

50 See CFPB, “What does it mean to ‘default’ on my federal student loans?” press release, August 4, 2016, at
https://www.consumerfinance.gov/ask-cfpb/what-does-it-mean-to-default-on-my-federal-student-loans-en-649/.
51 See CRS Report R40122, Federal Student Loans Made Under the Federal Family Education Loan Program and the
William D. Ford Federal Direct Loan Program: Terms and Conditions for Borrowers, by David P. Smole.
52 See Experian, “What is student loan rehabilitation?” February 3, 2020, at https://www.experian.com/blogs/ask-
experian/what-is-student-loan-rehabilitation/.
53 CFPB, Private Student Loans, Report to the Senate Committee on Banking, Housing, and Urban Affairs, the Senate
Committee on Health, Education, Labor, and Pensions, the House of Representatives Committee on Financial Services,
and the House of Representatives Committee on Education and the Workforce, August 29, 2012, at
http://files.consumerfinance.gov/f/201207_cfpb_Reports_Private-Student-Loans.pdf.
54 P.L. 115-174, §601 prohibits a private student loan lender from accelerating a debt or declaring a default against a
student loan borrower upon the bankruptcy or death of a co-signer. Section 601 also releases a co-signer from the debt
obligation upon the death of the student.
55 After 120-180 days, a depository firm may hire a debt collector, who receives a percentage of the collected amount,
or sell the defaulted loan outright to a collection agency. The debt collection process is guided by the Fair Debt
Collection Practices Act (P.L. 90-321).
56 See Office of the Comptroller of the Currency, Comptroller’s Handbook, Version 1.0, May 2016, p. 34, at
https://www.occ.treas.gov/publications/publications-by-type/comptrollers-handbook/student-lending/pub-ch-student-
lending.pdf.
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practices result in variation of the timing with which unpaid debts appear on consumer reports.
For example, medical providers may assign unpaid bills to debt collectors or sell outstanding
debts to debt buyers. Some medical providers may assign or sell the debt after 60 days, but some
may do so after 30 days (by comparison, most bank credit card delinquencies are assigned or sold
after 180 days). Some firms may turn obligations over to collections as a tool to encourage
consumers to settle unpaid balances, blurring the distinction between billing and collecting
policies.59 Debt collectors or buyers subsequently furnish negative information to CRAs, causing
tradeline accounts to sometimes appear on consumer reports.
The CFPB used a random sample of approximately 5 million consumers as of December 2012 to
determine what types of tradeline accounts were reported most frequently and the amounts.60 The
CFPB found that approximately 33% of credit reports surveyed had collection tradelines, and
approximately 52% of those collection tradelines were related to medical collections. After
medical obligations, the CFPB found that the remaining collection tradelines of significant
relevance were associated with unclassified debts (17.3%), cable or cellular bills (8.2%), utilities
(7.3%), and retail stores (7.2%). All other categories of collectible tradelines were approximately
2% or less of the survey. For 85% of the respondents, the amounts owed for medical debt were
for less than $1,000. In short, more than half of collection tradelines were associated with medical
debt, and they were for relatively small amounts. Specifically, the median amount owed for the
medical collection tradelines was $207, and 75% of all medical collection tradelines were under
$490.
One form of consumer debt—medical debt—is most often disputed by consumers and raises
specific policy issues related to inconsistent billing and reporting practices. According to the
CFPB study, consumers are unlikely to know when and how much various medical services cost
in advance, particularly those associated with accidents and emergencies. People often have
difficulty understanding co-pays and health insurance deductibles.61 Consequently, consumers
may delay paying medical obligations as they either assume their insurance companies will pay or
attempt to figure out why they have been billed, which often results in medical debt appearing
unpaid on credit reports.
Regulators and industry have taken actions that may reduce medical tradelines and their
associated negative effects on consumer credit data. On December 31, 2014, the Internal Revenue
Service (IRS) announced a final rule requiring the separation of billing and collection policies of
nonprofit hospitals.62 Under the rule, hospitals that have or are pursuing tax-exempt status are
required to make reasonable efforts to determine whether their patients are eligible for financial
assistance before engaging in “extraordinary collection actions,” which may include turning a

57 Title III of H.R. 3621.
58 For more information, see CRS Report R45339, Banking: Current Expected Credit Loss (CECL), by Raj Gnanarajah.
59 See CFPB, Consumer Credit Reports: A Study of Medical and Non-Medical Collections, December 2014, p. 36, at
http://files.consumerfinance.gov/f/201412_cfpb_reports_consumer-credit-medical-and-non-medical-collections.pdf.
Other firms may not immediately employ a collections strategy to encourage repayment of obligations for fears of
reputational risk.
60 See CFPB, Consumer Credit Reports: A Study of Medical and Non-Medical Collections, December 2014, at
http://files.consumerfinance.gov/f/201412_cfpb_reports_consumer-credit-medical-and-non-medical-collections.pdf.
61 Confusion about costs and co-pays may increase when medical care is administered outside of a consumer’s state of
residence, given that health insurers and providers determine costs that vary and are influenced by state regulations. See
CRS In Focus IF10043, Introduction to Financial Services: Insurance, by Baird Webel.
62 See Department of the Treasury, Internal Revenue Service, New Requirements for 501(c)(3) Hospitals Under the
Affordable Care Act, at https://www.irs.gov/charities-non-profits/charitable-organizations/requirements-for-501c3-
hospitals-under-the-affordable-care-act-section-501r.
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debt over to a collection agency (thus creating a medical tradeline) or garnishing wages. In short,
tax-exempt hospitals must allow patients 120 days from the date of the first billing statement to
pay the obligation before initiating collection procedures.63 The IRS rule only impacts nonprofit
hospitals, but, on September 15, 2017, the three major credit reporting agencies—Experian,
Equifax, and TransUnion—established a 180-day (6 month) waiting period before posting a
medical collection of any type on a consumer credit report.64 In addition, P.L. 115-174, Section
302, amended the FCRA to provide credit reporting protections for veterans as follows:
 CRAs must exclude certain medical debt incurred by a veteran from his or her
credit report if the hospital care or medical services relating to the debt predates
the credit report by less than one year.
 CRAs must remove from the credit report a veteran’s fully paid or settled
medical debt previously characterized as delinquent, charged off, or in collection.
 CRAs must establish a dispute process and verification procedures for veterans’
medical debt.
 Active duty military personnel receive free credit monitoring.
H.R. 3621 would impose restrictions on the appearance of medical collections on consumer credit
reports, extending the CRA’s 2017 rule to 365 days and excluding all debts related to medically
necessary care.65 The bill would also require expedited removal of all fully repaid or settled
medical debts.66
Consumer Rights in the Credit Reporting System
Consumers sometimes find it difficult to advocate for themselves when credit reporting issues
arise because they are not aware of their rights and how to exercise them. According to a CFPB
report, some consumers are confused about what credit reports and scores are, find it challenging
to obtain credit reports and scores, and struggle to understand the contents of their credit reports.67
The CFPB receives more credit reporting complaints than complaints in any other industry it
regulates.68 Currently, the CFPB provides financial education resources on its website to help
educate consumers about their rights regarding consumer reporting. The credit bureaus’ websites
also provide information about how to dispute inaccurate information, and consumers can contact
them by phone or mail.
H.R. 3621 would require that CRAs provide free credit scores in their annual free credit report.69
The bill also would allow consumers to be entitled to free credit reports at other times, for
example, whenever they apply for a new mortgage, auto loan, or student loan, or if a consumer’s

63 See Department of the Treasury, Internal Revenue Service, “Additional Requirements for Charitable Hospitals;
Community Health Needs Assessments for Charitable Hospitals; Requirements of a Section 4959 Excise Tax Return
and Time for Filing the Return,” 79 Federal Register 78954-79016, December 31, 2014.
64 See Experian, “Medical Debt and Your Credit Score: Here’s What You Need to Know,” press release, August 8,
2017, at https://www.experian.com/blogs/ask-experian/medical-debt-and-your-credit-score/.
65 §403 of H.R. 3621.
66 §403 of H.R. 3621.
67 CFPB, Consumer Voices on Credit Reports and Scores, February 2015, https://files.consumerfinance.gov/f/
201502_cfpb_report_consumer-voices-on-credit-reports-and-scores.pdf.
68 CFPB, Complaint Snapshot: Mortgage, January 2019, pp. 3-6, at https://files.consumerfinance.gov/f/documents/
cfpb_complaint-snapshot-mortage_2019-01_liwsYNV.pdf.
69 Title II of H.R. 3621.
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identity is stolen. The report and score used to make underwriting decisions in connection with
these events would be provided to the consumer. H.R. 3621 would also direct the credit bureaus
to give consumers more information on dispute rights, and it would require hard inquiries to be
limited for a longer 120-day shopping window for certain consumer credit products70 (as
described in the box “Some Factors Frequently Used to Calculate Credit Scores” above).
Appropriate Purposes for Using Credit Bureau Data:
Employment Decisions
Policy questions exist regarding the appropriate uses of credit bureau data, particularly for uses
outside of extending credit to consumers.71 For example, credit information can be used for
employment decisions. According to the Society for Human Resource Management (a human
resources professional society), in 2012, almost half of surveyed organizations in their
membership used credit background checks on some of their job applications.72 Employers report
that they use this information to reduce the likelihood of employee theft or embezzlement and to
reduce legal liability for negligent hiring.73 To comply with the FCRA, employers must inform an
applicant that his or her credit report is a part of a hiring decision, and acquire the applicant’s
written permission to obtain the report. If an applicant is denied a job, or if the employer takes
another adverse action due to information on a credit report, then the applicant must be given a
copy of the report and a summary of their FCRA rights.74
Whether the use of credit information in employment decisions unnecessarily harms prospective
job applicants is debatable. For some occupations, past financial difficulties may increase the
likelihood, for example, that the employee could be bribed or compromised in some way;
however, this information may not be essential for success in all occupations. Currently, many
states limit employers’ use of credit information for employment decisions.75 H.R. 3621 would
ban the use of credit information for employment decisions, unless required by law or for a
national security investigation.76
Consumers with Limited Credit Histories and Use of Alternative
Scoring Methods
The CFPB estimates that credit scores cannot be generated for approximately 20% of the U.S.
population due to their limited credit histories.77 The CFPB distinguishes between different types

70 §102 and §705 of H.R. 3621.
71 Whether credit information should be used in insurance decisions is also a topic of congressional interest, see H.R.
1756.
72 Society for Human Resource Management (SHRM), Background Checking—The Use of Credit Background Checks
in Hiring Decisions, July 19, 2012, at https://www.shrm.org/hr-today/trends-and-forecasting/research-and-surveys/
pages/creditbackgroundchecks.aspx.
73 SHRM, Background Checking—The Use of Credit Background Checks in Hiring Decisions.
74 FTC, Using Credit Reports: What Employers Need to Know, October 2016, at https://www.ftc.gov/tips-advice/
business-center/guidance/using-consumer-reports-what-employers-need-know.
75 Rosemarie Lally, Using Workers’ Credit Information Increasingly Prohibited, Society for Human Resource
Management, July 28, 2015, at https://www.shrm.org/resourcesandtools/legal-and-compliance/state-and-local-updates/
pages/states-credit-history.aspx.
76 Title VI of H.R. 3621.
77 For more information on credit access policy issues, see CRS Report R45979, Financial Inclusion and Credit Access
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of consumers with limited credit histories.78 One category of consumers, referred to as credit
invisibles, have no credit record at the three largest credit bureaus and, thus, do not exist for the
purposes of credit reporting. According to the CFPB, this group represents 11.0% of the U.S.
adult population, or 26 million consumers. Another category of consumers do exist (have a credit
record), but they still cannot be scored or are considered nonscorable. Nonscorable consumers
either have insufficient (short) histories or outdated (stale) histories. The insufficient and stale
unscored groups, each containing more than 9 million individuals, collectively represent 8.3% of
the U.S. adult population, or approximately 19 million consumers according to the CFPB.
Younger adults may be part of the credit invisible or nonscorable population because they lack a
sufficient credit history. As consumers get older, however, the problem of being credit invisible or
belonging to the insufficient part of the nonscorable group typically declines, but may begin to
reoccur after the age of 60. Older adults, who may have considerably reduced their credit usage,
perhaps as they prepare to enter retirement years, may encounter the problem of having stale
credit records.79 Because credit scoring models vary by firms, consumers that cannot be scored by
some models might still have the ability to be scored by other models; thus, the state of being
nonscorable may depend upon the credit reporting data records and scoring models used.
Borrowers with missing or impaired credit histories may be able to improve their ability to get
reliable credit scores by using credit building loans, such as secured credit cards that require
either security deposits as collateral for the amount of the line of credit or links to checking or
savings accounts, thereby allowing lenders to recover funds if payments are missed. The security
deposit is refunded if borrowers do not miss payments. Secured credit card lending can help
borrowers build or repair their credit histories, assuming that the more favorable customer
payment activity is reported to credit bureaus. In addition, the use of alternative credit scores may
also help the credit invisibles because other types of consumer payment activity (discussed
below) may be predictive in regard to how borrowers would manage credit. In short, options that
increase the ability to calculate scores for the invisible or currently nonscoreable consumer
groups could allow lenders to better determine the quantity and scope of financial relationships
they can establish with such groups.
Alternative credit scoring models could potentially increase accuracy by including additional
information beyond that which is traditionally included in a credit report. For example, some
credit score models do not distinguish between unpaid and paid (resolved) tradelines.80 Most
credit scores are calculated without utility and rent payments information. Arguably, including
this information would benefit the credit scores for some individuals with limited or no credit
histories, potentially increasing their access to—and lowering their costs of—credit.81 Conversely,
information about medical debts has often been included in credit scores, but the unevenness in
medical reporting, as previously discussed, and possibly the consumers’ lack of choice in
incurring medical debt raises questions about whether medical debt tradelines should be

Policy Issues, by Cheryl R. Cooper.
78 See Kenneth P. Brevoort, Philipp Grimm, and Michelle Kambara, Data Point: Credit Invisibles, CFPB, May 2015, at
http://files.consumerfinance.gov/f/201505_cfpb_data-point-credit-invisibles.pdf.
79 The CFPB estimated some additional information about these groups by age, income, and race. See Kenneth P.
Brevoort, Philipp Grimm, and Michelle Kambara, Data Point: Credit Invisibles, CFPB, May 2015, at
http://files.consumerfinance.gov/f/201505_cfpb_data-point-credit-invisibles.pdf.
80 The treatment of paid and unpaid collection tradelines varies among different credit scoring models. See “New FICO
Score Model Could Boost Credit for Millions—Medical Bills in Focus,” NerdWallet, August 8, 2014, at
http://www.nerdwallet.com/blog/health/2014/08/08/new-fico-score-boost-credit-medical-bills-focus/.
81 Experian, New Study Shows How Alternative Payment Data Helps U.S. Consumers’ Credit Profiles, February 25,
2015, at https://www.experianplc.com/media/news/2015/alternative-data-to-credit-reports-utilities-and-rent-2015/.
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considered reliable predictors of creditworthiness or credit performance.82 For this reason, some
newer versions of credit scoring apply less weight to medical debt.83 In short, developing credit
scores with new information might allow lenders to find new creditworthy consumers.
Regulators and Congress have considered the potential for alternative credit scoring. In 2014, the
Federal Housing Finance Agency (FHFA) directed Fannie Mae and Freddie Mac—the
government-sponsored enterprises (GSEs) that purchase mortgages in the secondary market—to
consider using more updated credit scoring models in their mortgage underwriting.84 Under P.L.
115-174, FHFA is required to define, through rulemaking, the standards and criteria the GSEs will
use for validating credit score models used when evaluating whether to purchase a residential
mortgage.85 If enacted, H.R. 3621 would direct the CFPB to report to Congress on the impact of
using nontraditional data on credit scoring.86
Full implementation of newer versions of credit scoring models, however, may not occur
quickly.87 In the mortgage market, upgrading automated underwriting systems is costly for the
GSEs, FHA, and loan originators. Not all originators will choose to update their automated
underwriting systems.88 Even if alternative credit scoring models were widely adopted, the credit
score is not the only variable considered during the underwriting process. Just as several factors
are included in the development of a credit score, a credit score is only one of several factors
included in an automated underwriting model (also referred to as an underwriting scorecard).89
The debt-to-income ratio, for example, may still be an important variable for mortgage
underwriting. Higher levels of medical and student loan debts may still affect mortgage
underwriting decisions.90 Hence, the use of alternative credit scores may help some borrowers

82 See Kenneth P. Brevoort and Michelle Kambara, Data Point: Medical Debt and Credit Scores, CFPB, May 2014, at
http://files.consumerfinance.gov/f/201405_cfpb_report_data-point_medical-debt-credit-scores.pdf.
83 See John Ulzheimer, “New FICO Score Coming Soon to a Credit Bureau Near You,” Credit Sesame Daily, August
7, 2014, at http://www.creditsesame.com/blog/new-fico-score-coming-soon/.
84 See Kevin Wack, “Fannie, Freddie to Evaluate Alternative Scoring Models,” American Banker, September 22, 2014,
at http://www.americanbanker.com/issues/179_183/fannie-freddie-to-evaluate-alternative-credit-scoring-models-
1070140-1.html. Similarly, the Federal Housing Administration (FHA), which provides federal mortgage insurance, is
also considering whether to use updated versions of credit scoring models. See National Association of Realtors, “HUD
Secretary Tells Realtors that FHA is Exploring Alternative to Credit Scoring Models to Expand Mortgage Access,”
news release, April 1, 2015, at http://www.realtor.org/news-releases/2015/04/hud-secretary-tells-realtors-fha-is-
exploring-alternative-credit-scoring-models-to-expand-mortgage.
85 Specifically, the law allows Fannie Mae and Freddie Mac to employ alternative credit scoring models when
purchasing mortgages rather than rely exclusively on the FICO scoring model. See Federal Housing Finance Agency,
FHFA Announces Decision to Stop Credit Score Initiative: No Decision in 2018; Focus Shifts to Implementing New
Law, News Release, July 23, 2018, at https://www.fhfa.gov/Media/PublicAffairs/Pages/FHFA-Announces-Decision-to-
Stop-Credit-Score-Initiative.aspx.
86 §501 of H.R. 3621.
87 See Mary Ellen Podmolik, “Rollout is Slow for FICO’s New Credit Scoring Model,” Chicago Tribune, October 14,
2014, at http://www.chicagotribune.com/classified/realestate/ct-mre-1019-podmolik-homefront-20141014-
column.html.
88 See Adrian Nazari, “How FICO’s New Credit Score Will Impact Consumers,” Huffington Post, September 19, 2014,
at http://www.huffingtonpost.com/adrian-nazari/how-ficos-new-credit-score-will-impact-consumers_b_5844530.html.
89 An underwriting scorecard may include information such as income, assets, and employment history obtained from
the borrower’s application not taken into account while preparing the credit score. See Federal Deposit Insurance
Corporation, Credit Card Activities Manual, Chapter VIII.-Scoring and Modeling, March 2007, at
https://www.fdic.gov/regulations/examinations/credit_card/pdf_version/ch8.pdf; and Cary Collins, Keith D. Harvey,
and Peter Nigro, “The Influence of Bureau Scores, Customized Scores, and Judgmental Review on the Bank
Underwriting Decision-Making Process,” Journal of Real Estate Research, vol. 24, no. 2 (2002), pp. 129-152.
90 Carrying higher levels of debt may become an equally or, under some circumstances, a more important factor in
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close to a threshold or borderline, yet still not translate into significant changes in credit access
across the board.
Data Protection and Security Issues
Congressional interest in data protection and security in the consumer data industry has increased
following the announcement, on September 7, 2017, of the Equifax cybersecurity breach that
potentially revealed sensitive consumer data information for 143 million U.S. consumers.91 CRAs
are subject to the data protection requirements of Section 501(b) of the Gramm-Leach-Bliley Act
(GLBA).92 Section 501(b) requires the federal financial institution regulators to “establish
appropriate standards for the financial institutions subject to their jurisdiction relating to
administrative, technical, and physical safeguard—(1) to insure the security and confidentiality of
consumer records and information; (2) to protect against any anticipated threats or hazards to the
security or integrity of such records; and (3) to protect against unauthorized access or use of such
records or information which could result in substantial harm or inconvenience to any
customer.”93
The CFPB does not have the authority to prescribe regulations with regard to safeguarding the
security and confidentiality of customer records.94 Instead, the FTC has the authority to enforce
Section 501(b) as the federal functional regulator of nonbank financial institutions, including
CRAs.95 The FTC has promulgated rules implementing the GLBA requirement.96 Because the
FTC has little upfront supervisory or enforcement authority, the agency typically must rely upon
its enforcement authority after an incident has occurred. In addition, in March 2019, the
Government Accountability Office released a report that recommended actions for the FTC, the
CFPB, and Congress to strengthen oversight of credit bureaus’ data security.97 If enacted, H.R.

mortgage approval decisions relative to other factors in light of recently adopted mortgage underwriting requirements.
See “How the New FICO Score Model Will Affect Banks,” American Banker, August 13, 2014, at
http://www.americanbanker.com/issues/179_156/how-the-new-fico-score-model-will-affect-banks-1069413-1.html.
91 See Equifax, “Equifax Announces Cybersecurity Incident Involving Consumer Information,” press release,
September 7, 2017, at https://www.equifaxsecurity2017.com/2017/09/07/equifax-announces-cybersecurity-incident-
involving-consumer-information/.
On October 2, 2017, Equifax announced that an additional 2.5 million consumers may have been affected, for a total of
145.5 million. See, “Equifax Announces Cybersecurity Firm has Concluded Forensic Investigation of Cybersecurity
Incident,” press release, October 2, 2017, at https://investor.equifax.com/news-and-events/news/2017/10-02-2017-
213238821.
92 See CRS Insight IN11199, Big Data in Financial Services: Privacy and Security Regulation, by Andrew P. Scott;
and CRS Report R44429, Financial Services and Cybersecurity: The Federal Role, by N. Eric Weiss and M. Maureen
Murphy.
93 See 15 U.S.C. §6801 and CRS Insight IN10792, The Equifax Data Breach: An Overview and Issues for Congress, by
N. Eric Weiss.
94 See CRS Testimony TE10021, Consumer Data Security and the Credit Bureaus, by Chris Jaikaran.
95 GLBA delegated the authority for federal consumer privacy provisions to the federal banking regulators for federally
insured depository institutions; the Securities and Exchange Commission for brokers, dealers, investment companies,
and investment advisors; state insurance regulators for insurance companies; and the FTC for all other financial
institutions. See CRS Report R44429, Financial Services and Cybersecurity: The Federal Role, by N. Eric Weiss and
M. Maureen Murphy.
96 FTC, “Privacy of Consumer Financial Information,” 65 Federal Register 33646-33689, May 24, 2000.
97 U.S. Government Accountability Office, Consumer Data Protection: Actions to Strengthen Oversight of Consumer
Reporting Agencies, GAO-19-196, February 2019, at https://www.gao.gov/products/GAO-19-196.
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3621 would allow the CFPB to supervise and enforce cybersecurity standards for credit reporting
agencies.98
Meanwhile, P.L. 115-174, Section 301, requires credit bureaus to provide fraud alerts for
consumer files for at least a year under certain circumstances. In addition, credit bureaus must
provide consumers with one free freeze alert and one free unfreeze alert per year. The law also
established further requirements to protect minors. Currently, many credit bureaus provide
consumers services such as credit monitoring for identity theft victims. In general, credit bureaus
charge fees for these services, paid for by either a consumer or private company after a data
breach incident. H.R. 3621 would expand protections for identity theft victims, including the right
to free credit monitoring and identity theft services.99 It would require the CFPB to create new
regulations to define the parameters for these new consumer benefits, including how long they
should be provided and what services should be included.100

98 §910 of H.R. 3621.
99 Title VIII of H.R. 3621.
100 §808 of H.R. 3621.
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Appendix. Natural Disasters, Government
Shutdowns, and the COVID-19 (Coronavirus
Disease 19) Pandemic
Many consumers may experience disruptions in their income following unexpected events, such
as natural disasters, government shutdowns, or a pandemic and, therefore, are likely to be
delinquent or default on loans and other regularly scheduled payments. For example, from
December 22, 2018, to January 25, 2019, the federal government shut down for five weeks,
raising concerns that federal employees may experience difficulties meeting their scheduled
payment obligations that might subsequently affect their credit records and future credit scores.
Likewise, a growing number of cases of Coronavirus Disease 2019 (COVID-19) were identified
in the United States during the early spring of 2020, significantly impacting many
communities.101 As this situation rapidly evolves, the economic impact is likely to be large due to
illnesses, quarantines, and other business disruptions.102 Consequently, many Americans may lose
income and face financial hardship.103
Lenders have various options to mitigate the impact on consumers’ credit scores and future credit
access following disasters or catastrophic events. For example, furnishers may use special codes
to report delinquencies due to special circumstances.104 Financial institutions also may agree to
limit late or other fees. Lenders offer forbearance plans, which are agreements that allow
extended time for consumers to become current on their payments. However, some of these
efforts may be more difficult for some institutions if they require changes in credit contracts. If
lenders and consumers enter into loan forbearance agreements, then furnishers have the option to
report to the credit bureaus that these consumers are current on their credit obligations.
Congress has also responded to mitigate the financial consequences of an adverse event on
consumers. For example, various bills were introduced during the federal shutdown to allow
credit restoration for some affected consumers.105 In addition, on March 27, 2020, in response to
the COVID-19 pandemic, the President signed the Coronavirus Aid, Relief, and Economic
Security Act (CARES Act; P.L. 116-136).106 Section 4021 of this bill requires furnishers during
the COVID-19 pandemic covered period to report to the credit bureaus that consumers are current
on their credit obligations if they enter into an agreement to defer, forbear, modify, make partial
payments, or get any other assistance on their loan payments from a financial institution and fulfil

101 For background on COVID-19 (Coronavirus Disease 2019), see CRS In Focus IF11421, COVID-19: Global
Implications and Responses, by Sara M. Tharakan et al.
102 For more information on the effects of COVID-19 on the U.S. economy, see CRS Insight IN11235, COVID-19:
Potential Economic Effects, by Marc Labonte.
103 For more information on financial industry policy issues during the COVID-19 outbreak for consumers having
trouble paying their bills, see CRS Insight IN11244, COVID-19: The Financial Industry and Consumers Struggling to
Pay Bills, by Cheryl R. Cooper.
104 During natural disasters, lenders have the ability to flag affected borrowers by using special comment codes when
reporting to credit bureaus. See CFPB, Natural Disasters and Credit Reporting: Quarterly Consumer Credit Trends,
November 2018, https://files.consumerfinance.gov/f/documents/bcfp_quarterly-consumer-credit-trends_report_2018-
11_natural-disaster-reporting.pdf.
105 For example, H.R. 935, H.R. 799, H.R. 1286, and S. 535. House Financial Services Committee Chairwoman
Maxine Waters also released a related draft bill, “Protecting Innocent Consumers Affected by a Shutdown Act.”
106 CRS Report R46301, Title IV Provisions of the CARES Act (P.L. 116-136), coordinated by Andrew P. Scott.
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those requirements, provided they were current before this period.107 The covered period starts on
January 31, 2020, and extends to the later of 120 days after enactment or 120 days after the
national emergency declared by the President on March 13, 2020, terminates. In other words,
prior to the CARES Act lenders could choose whether to report loans in forbearance as paid on
time. Under the CARES Act, lenders must report such obligations as paid on time. However,
some affected consumers may still experience harm to their credit record because lenders
generally can still choose whether to enter into an assistance agreement with an individual
consumer.
The CARES Act grants all consumers a right to request forbearance for many types of
mortgages108 and for federal student loans.109 In addition, financial regulators have encouraged
lenders to work with consumers affected by the outbreak,110 and many financial institutions have
announced efforts to provide assistance to affected consumers.111 However, for many types of
consumer loans, such as auto loans and credit cards, different financial institutions may be subject
to different laws and incentives to handle consumer relief requests.112 Therefore, a consumer’s
ability to access loan forbearance may vary, and some consumers may still experience harm to
their credit record.
On May 15, 2020, the House passed the HEROES Act (H.R. 6800). Section 110401 of the bill
would create a moratorium on furnishing adverse information to credit bureaus during the
COVID-19 pandemic and for 120 days afterward, as well as for other future major natural
disasters.113 Consumers could request to delete adverse information during the covered period and
for 270 days afterward if experiencing economic hardship. Medical debt related to treatments
arising from COVID-19 or another major disaster would not be furnished or included in the credit

107 If the consumer was delinquent before the covered period, then the furnisher should maintain the delinquent status
unless the consumer brings the account or obligation current. For more information, see CFPB, Statement on
Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the
CARES Act, April 1, 2020, at https://files.consumerfinance.gov/f/documents/cfpb_credit-reporting-policy-
statement_cares-act_2020-04.pdf.
108 §4022 gives consumers the right to request a forbearance and provides a moratorium on foreclosures on loans that
are either (1) insured or guaranteed under provisions of the National Housing Act (12 U.S.C. §1707 et seq., 12. U.S.C.
§1715z-20); (2) guaranteed under §184 or §184A of the Housing and Community Development Act (12 U.S.C.
§1715z-13a, §1715z-13b); (3) guaranteed or insured by the Department of Veterans Affairs or (including those made
by) Department of Agriculture; or (4) purchased or securitized by Freddie Mac or Fannie Mae.
109 §3513 suspends all payments due for loans made under part D and part B (that are held by the Department of
Education) of title IV of the Higher Education Act of 1965 ( 20 U.S.C. §1087a et seq.; §1071 et seq.) through
September 30, 2020. Any payment that has been suspended will be treated as if it were a regularly scheduled payment
made by a borrower for the purpose of reporting information about the loan to a consumer reporting agency.
110 On Monday, March 9, federal and state financial regulators coordinated a statement to the financial industry,
encouraging it to help meet the needs of consumers impacted by the coronavirus outbreak. They stated that “financial
institutions should work constructively with borrowers and other consumers in affected communities,” as long as they
take “prudent efforts that are consistent with safe and sound lending practices.” See Federal Reserve Board et al.,
Agencies Encourage Financial Institutions to Meet Financial Needs of Customers and Members Affected by
Coronavirus, March 9, 2020, at https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200309a.htm.
111 Jessica Menton, “Contact Your Mortgage Lender: Payments May Be Deferred as Coronavirus Pandemic Causes
Worker Hardships,” USA Today, March 22, 2020, at https://www.usatoday.com/story/money/2020/03/20/coronavirus-
mortgage-payments-may-deferred-amid-pandemic/5073179002/.
112 For more information on consumer loan forbearance during the COVID-19 pandemic, including the impact of the
CARES Act and other federal regulatory efforts, see CRS Report R46356, COVID 19: Consumer Loan Forbearance
and Other Relief Options, coordinated by Cheryl R. Cooper.
113 For more information on HEROES Act consumer loan provisions, see CRS Insight IN11405, HEROES Act (H.R.
6800): Selected Consumer Loan Provisions, by Cheryl R. Cooper.
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report. New credit scoring models could not be implemented during a major natural disaster
period if they would identify a significant percentage of consumers as being less creditworthy
than the previous model. Although these provisions would protect consumers from lower credit
scores during the COVID-19 pandemic, the removal of information may also reduce credit
scores’ predictability in the future, which could harm some consumers in the long term.114

Author Information

Cheryl R. Cooper
Darryl E. Getter
Analyst in Financial Economics
Specialist in Financial Economics

Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in
its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or
material from a third party, you may need to obtain the permission of the copyright holder if you wish to
copy or otherwise use copyrighted material.

114 For more information about the policy options and consequences of different credit reporting approaches during the
COVID-19 pandemic, see FinRegLab, Disaster-Related Credit Reporting Options, May 2020, https://finreglab.org/wp-
content/uploads/2020/05/FinRegLab-Disaster-Related-Credit-Reporting.pdf.
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