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When running a credit report on a new applicant, you must ensure Fair Credit Reporting Act (FCRA) compliance before accessing, using and sharing the collected data. The Coronavirus Aid, Relief, and Economic Security (CARES) Act has impacted credit reporting under the FCRA, as has new guidance from the Consumer Financial Protection Bureau (CFPB). Recent updates include: The CARES Act amended the FCRA to require furnishers who agree to an “accommodation,”1 to report the account as current, although it is permitted to continue to report the account as delinquent if the account was delinquent before the accommodation was made. Although not legally obligated, data furnishers should continue furnishing information to the credit reporting agencies (CRAs) during the COVID-19 crisis, and make sure that information reported is complete and accurate. Below is a brief FCRA-related compliance overview2 covering various FCRA requirements3 when requesting and using consumer credit reports for an extension of credit permissible purpose. For more information regarding your responsibilities under the FCRA as a user of consumer reports, please consult your Legal Counsel and the Notice to Users of Consumer Reports: Obligations of Users Under the FCRA handbook located on our website. Before obtaining a consumer report you have…  Reviewed your federal and state regulations and laws related to consumer reports, scores, decisions, etc.  Made sure you have a valid permissible purpose for pulling the consumer report.  Certified compliance to the CRA from which you are getting the consumer report. You have certified that you complied with all the federal and state requirements. After you take an adverse action based on a consumer report you… Provide the consumer with an oral, written or electronic notice of the adverse action. Provide written or electronic disclosure of the numerical credit score used to take the adverse action, or when providing a “risk-based pricing” notice. Provide the consumer with an oral, written or electronic notice, which includes the below information:  Name, address and telephone number of CRA that supplied the report, if nationwide. A statement that the CRA did not make the adverse decision and therefore can’t explain why the decision was made.  Notice of the consumer’s right to a free copy of their report from the CRA, if requested within 60 days.  Notice of the consumer’s right to dispute with the CRA the accuracy or completeness of any information in a consumer report provided by the CRA. Provide the consumer with a “risk-based pricing” notice if credit was granted but on less favorable terms based on information in their consumer report. We understand how challenging it is to understand and meet all your obligations as a data furnisher – we’re here to make it a little easier. Click below to speak with a representative and gain more insight on how the CARES Act impacts FCRA reporting. Download overview Speak with a representative 1An “accommodation” is defined as “an agreement to defer one or more payments, make a partial payment, forbear any delinquent amounts, modify a loan or contract, or any other assistance or relief” granted to a consumer affected by COVID-19 during the covered period. 2This FCRA overview is not legal guidance and does not enumerate all your requirements under the FCRA as a user of consumer reports. Additionally, this FCRA Overview is not intended to provide legal advice or counsel you regarding your obligations under the FCRA or any other federal or state law or regulation. Should you have any questions about your institution’s specific obligations under the FCRA or any other federal or state law or regulation, you should consult with your Legal Counsel. 3This FCRA overview is intended to be used solely by financial service providers when extending credit to consumers and does not include all FCRA regulatory obligations. You are responsible for regulatory compliance when requesting and using consumer reports, which includes adhering to all applicable federal and state statutes and regulations and ensuring that you have the correct policies and procedures in place.

There is no doubt that there will be many headlines published about the latest Bureau of Labor Statistics (BLS) jobs report. The official unemployment rate spiked to 14.7%, the highest level since the Great Depression, and employers shed an unprecedented 20.5 million jobs. However, given the scale and pace that businesses around the country are adjusting their workforces, these headline numbers – especially the official unemployment rate – fall short in capturing the nuances and internal dynamics of the crisis. To get a better picture of labor market health in the coming months, there are three other components reported in BLS’s employment release that require close attention: the underemployment rate, the labor force participation rate, and the employment-population ratio. Tracking underemployment The BLS reports six unemployment figures in its monthly employment release, U1 – U6. The most cited is the “official” unemployment rate, which is U3. However, in the current crisis, the more salient measure of unemployment is U6, which is often known as the “underemployment” rate. This is because the underemployment (U6) rate takes the unemployed and adds on part-time workers who want a full-time job (BLS calls this segment “part time for economic reasons”), plus marginally attached and discouraged workers (those who don’t think they can find work). Viewing the employment landscape through this lens provides greater insight into the pain points within the labor market. In April, the underemployment rose from 8.7% to 22.8% – the largest jump on record. A large contributor to the rise was a doubling of the number of part-time workers that wanted a full-time job. Mirroring what happened in previous downturns, the rise in this segment was caused by employers downshifting workers into part-time roles. The official unemployment rate will miss this insight as it classifies everyone who is working as “employed”, regardless if they worked one hour or 100 hours. Trends in the underemployment rate will be especially important to watch as the recovery gets underway. If employers are doubtful of a strong rebound, they may keep employees on as part time and forgo filling any full-time positions. Who’s in and who’s out of the labor force The labor force participation rate is the percentage of the working-age population (aged 16+) that is employed or searching for a job. A decline in the labor force participation rate means that people are leaving the workforce and are no longer looking for employment. April’s employment report showed labor force participation declining from 62.7% to 60.2%. Teenage participation was especially hard hit, dropping from 35.5% to 30.8% – the lowest level since the government started collecting the data in 1948. During the recovery phase, tracking what happens with labor force participation will provide insight into how potential workers perceive their chances of landing a job and if it is safe to return. A healthy (or improving) labor market will bring people off the sidelines in search of work, while a weak labor market will do the opposite. Get a clearer view with the employment-population ratio In the current environment where people are bouncing rapidly between employed, unemployed, underemployed, and out of the labor force, tracking the employment-population ratio provides a more stable baseline to view the economic environment. The latest data shows that the employment-population ratio dropped to the lowest level on record of 51.3% in April. This means that only half of people who are of working age in the U.S. are currently employed in some form. Unlike the unemployment rate, which is calculated by dividing the number of unemployed workers by the labor force and thus subject to more variation as people start and stop looking for work, the employment to population ratio is the percentage of the total working-age population that is currently employed. By having a more stable baseline, it is easier to locate trends and see through the market gyrations. And finally, why it matters The labor market is the backbone of the economy and is the engine that powers the US consumer. But the ongoing crisis and rapid reallocation of the workforce has made it difficult to get a clear picture on what is happening at the ground level. By going beyond the headlines, businesses and financial institutions can glean nuanced insights that provide a better view of where the opportunities lie and how the recovery is likely to unfold. Learn more

This week, Experian released a new version of our CrossCore® digital identity and fraud risk platform, adding new tools and functionality to help businesses quickly respond to today’s emerging fraud threats. The ability to confidently recognize your customers and safeguard their digital transactions is becoming an increasing challenge for businesses. Fraud threats are already rising across the globe as fraudsters take advantage of the global health crisis and rapidly shifting economic conditions. CrossCore combines risk-based authentication, identity proofing and fraud detection into a single cloud platform, which means businesses can more quickly respond to an ever-changing environment. And with flexible decisioning orchestration and advanced analytics, businesses can make real-time risk decisions throughout the customer lifecycle. “Now more than ever, businesses need to lean on capabilities and technology that will allow them to rapidly respond in these challenging times, increase identity confidence in every transaction, and provide a safe and convenient experience for customers,” said E.K. Koh, Experian’s Senior Vice President of Global Identity & Fraud Solutions in a recent press release. “This new CrossCore release enables businesses to easily leverage best-in-class, pre-integrated identity and fraud services through simple self-service.” This new version of CrossCore features a cloud architecture, modern user interface, progressive risk assessments, faster response times, self-service workflow configuration, and a transactional volume reporting dashboard. These enhancements give you a simpler way to manage how backing applications are utilized, allow you to analyze key performance indicators in near real-time, and empower you to catch more fraud faster – without impacting the customer experience. “Recent Aite Group research shows that many banks have seen digital channel usage increase 250% in the wake of the pandemic, so ensuring a seamless and safe customer experience is more important than ever,” said Julie Conroy, Research Director at Aite Group. “Platforms such as CrossCore that can enable businesses to nimbly respond to changing patterns of customer behavior as well as rapidly evolving attack tactics are more important than ever, as financial services firms work to balance fraud mitigation with the customer experience.” CrossCore is the first identity and fraud platform that enables you to connect, access, and orchestrate decisions across multiple solutions. With the newest version, Experian enhances your ability to consolidate numerous fraud risk signals into a single, holistic assessment to improve operational processes, stay ahead of fraudsters, and protect your customers. Read Press Release Learn More About CrossCore