In establishing and implementing
its policies and procedures, a furnisher should:
(a) Identify practices or activities of the furnisher that can compromise
the accuracy or integrity of information furnished to consumer reporting
agencies, such as by:
(1) Reviewing its existing practices and
activities, including the technological means and other methods it
uses to furnish information to consumer reporting agencies and the
frequency and timing of its furnishing of information;
(2) Reviewing its historical
records relating to accuracy or integrity or to disputes; reviewing
other information relating to the accuracy or integrity of information
provided by the furnisher to consumer reporting agencies; and considering
the types of errors, omissions, or other problems that may have affected
the accuracy or integrity of information it has furnished about consumers
to consumer reporting agencies;
(3) Considering any feedback received from
consumer reporting agencies, consumers, or other appropriate parties;
(4) Obtaining feedback
from the furnisher’s staff; and
(5) Considering the potential impact of the furnisher’s policies
and procedures on consumers.
(b) Evaluate
the effectiveness of existing policies and procedures of the furnisher
regarding the accuracy and integrity of information furnished to consumer
reporting agencies; consider whether new, additional, or different
policies and procedures are necessary; and consider whether implementation
of existing policies and procedures should be modified to enhance
the accuracy and integrity of information about consumers furnished
to consumer reporting agencies.
(c) Evaluate the
effectiveness of specific methods (including technological means)
the furnisher uses to provide information to consumer reporting agencies;
how those methods may affect the accuracy and integrity of the information
it provides to consumer reporting agencies; and whether new, additional,
or different methods (including technological means) should be used
to provide information to consumer reporting agencies to enhance the
accuracy and integrity of that information.
