Last Thursday, the Bureau of Consumer Financial Protection (the “Bureau”) announced a settlement with State Farm Bank, FSB (“State Farm”) regarding alleged violations of the FCRA as well as the Consumer Financial Protection Act of 2010.  In the Consent Order, available here, the Bureau indicated that it found that State Farm violated the FCRA in numerous ways including: obtaining consumer reports without a permissible purpose; failing to promptly update or correct information furnished to credit-reporting-agencies (“CRAs”); furnishing information to CRAs without providing notice that the information was disputed by the consumer; and failing to establish and implement reasonable written policies and procedures regarding the accuracy of the information provided to CRAs.  State Farm did not admit or deny the Order’s findings of fact or conclusions of law.

Pursuant to the Consent Order, State Farm must implement and maintain reasonable written policies, procedures and processes to address the practices enumerated in the Consent Order.  Notably, the BFCP did not levy a monetary against State Farm, but if State Farm violates any of the terms of the Consent Order, the Bureau reserved the right to impose the maximum amount of civil penalties allowed by applicable law.