Advocacy Submits Comments on CFPB’s Proposed Rule on the Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V)

On August 5, 2024, the Office of Advocacy submitted comments on the Consumer Financial Protection Bureau’s (CFPB) notice of proposed rulemaking on Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (Regulation V).

The proposed rule would remove a regulatory exception in Regulation V from the limitation in the Fair Credit Reporting Act on creditors obtaining or using information on medical debts for credit eligibility determinations. The proposed rule would also provide that a consumer reporting agency generally may not furnish to a creditor a consumer report containing information on medical debt that the creditor is prohibited from using.

Advocacy expressed concerns about CFPB’s failure to provide adequate information about the economic impact of the proposal on small entities. Advocacy also questioned the necessity of the rulemaking since some states have enacted laws and the credit reporting industry has taken steps to address the issue.

Advocacy also encouraged CFPB to consider small entity alternatives, such as providing a longer implementation period for small entities.

For more information, please contact Assistant Chief Counsel Jennifer A. Smith, at Jennifer.Smith@sba.gov.

Document

Comment Letter – Prohibition on Creditors and Consumer Reporting Agencies Concerning Medical Information (PDF, 85.3 KB)