On Friday, March 27, 2020 the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was passed into law. The newly enacted provisions have the effect of impacting the manner in which financial institutions, including banks, non-bank lenders, and mortgage servicers engage in credit reporting as the country works through the ongoing COVID-19 pandemic.
Section 4021 of the CARES Act serves to amend the Fair Credit Reporting Act (FCRA) (15 U.S.C. 1681). It requires that a furnisher of credit reporting information that makes an accommodation to a consumer for one or more payments report the obligation as current if the consumer makes the payment(s) or is not required to. Alternatively, if the obligation was delinquent at the time of the accommodation, it should be reported delinquent unless brought current, at which time it should be reported as so. The reporting changes are to run from Jan. 31, 2020 to the later of 120 days following enactment of the legislation or 120 days after the end of the current national emergency that was declared on March 13, 2020.
