Regulation V Adds Protections for Human Trafficking Victims

The CFPB finalized amendments to Regulation V (Fair Credit Reporting) which allow victims of human trafficking to have any related adverse information removed from their consumer reports. The changes are effective on July 25, 2022.

The National Defense Authorization Act prohibits consumer reporting agencies from furnishing adverse information within a consumer report …that resulted from a severe form of trafficking in persons or sex trafficking if the consumer has provided trafficking documentation to the consumer reporting agency. It also required the CFPB to issue rules for what information consumers would need to submit to consumer reporting agencies and how they could do so.

These changes detail the information human trafficking victims must provide and the methods by which they need to be allowed to do so. The rule also outlines requirements and restrictions for consumer reporting agencies to receive and act upon notice that any adverse information is the result of human trafficking. Consumer reporting agencies must also post information on their websites, informing the public on how human trafficking victims can block adverse information from being reported.

The CFPB also put out a “Fast Facts” document that gives a high-level overview of these changes. While these changes do not impose any additional requirements on financial institutions, human trafficking is a heinous crime and financial institutions are needed on the front lines to help with detection and prevention. Unfortunately, we see constant reminders that human trafficking continues to run rampant so make sure any potential red flags are incorporated into your BSA/AML training programs.

Free Resources!Published
2022/06/30

Amendments

 

Diane Dean

Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!

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