April 24, 2020

AILA Members and Friends:

I want to send this brief note to clarify what may be a misconception concerning the granting of “accommodations” and credit reporting duties during the pandemic.

The CARES Act does have a section addressing credit reporting obligations on furnishers of data to a Credit Reporting Agency (“CRA”). Specifically, if an accommodation (forgiveness of payments, forbearance of payments, etc.) is granted to a customer, and the customer meets his or her obligation pursuant to the accommodation, then what would otherwise be a delinquent account must be reported as “current” (with limited exception). However, nothing in the CARES Act requires that a creditor offer any accommodation to a customer.

Please work with your CRA to make certain that you continue to report properly under the Fair Credit Reporting Act, as amended by the CARES Act.

I hope that you continue to weather the storm safely. Please let me know if I can answer any questions for you.


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