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Recommendations Database

GAO’s recommendations database contains report recommendations that still need to be addressed. GAO’s priority recommendations are those that we believe warrant priority attention. We sent letters to the heads of key departments and agencies, urging them to continue focusing on these issues. Below you can search only priority recommendations, or search all recommendations.

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As of October 25, 2020, there are 4812 open recommendations, of which 473 are priority recommendations. Recommendations remain open until they are designated as Closed-implemented or Closed-not implemented.

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Results:

Subject Term: "Credit reports"

4 publications with a total of 8 open recommendations
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Consumer Reporting Agencies: CFPB Should Define Its Supervisory Expectations
GAO-19-459, Jul 16, 2019
Director: Anna Maria Ortiz
Phone: (202) 512-8678

2 open recommendations
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Recommendation: The Director of CFPB should communicate to CRAs its expectations regarding reasonable procedures for assuring maximum possible accuracy of consumer report information. (Recommendation 1)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: In a January 2020 update, CFPB reemphasized statements made in its comment letter, including its expectation for CRAs to fully comply with applicable federal consumer financial laws and the role of case law in providing guidance to CRAs. CFPB additionally noted that its publicly available examination procedures discuss factors that CFPB will consider in evaluating compliance with the reasonableness standard under the Fair Credit Reporting Act (FCRA). CFPB stated that since publication of the report, it has taken actions to convey expectations to CRAs, including holding a joint workshop with FTC in December 2019 on consumer reporting accuracy and publishing a Supervisory Highlights special edition focused on consumer reporting. More direct communication of CFPB's expectations can provide CRAs with clearer information on what actions might constitute a FCRA violation and how CRAs should comply with the reasonableness standard. We maintain that providing additional information to CRAs about its expectations for key FCRA requirements could help CFPB to promote consistency and transparency in its supervisory approach and that the recommendation should be addressed.
Recommendation: The Director of CFPB should communicate to CRAs its expectations regarding reasonable investigations of consumer disputes. (Recommendation 2)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: In a January 2020 update, CFPB restated the requirements for a reasonable investigation under the Fair Credit Reporting Act (FCRA) and noted that court cases have articulated what qualifies as a reasonable investigation. CFPB also noted that a 2011 FTC report summarizes how the courts and FTC have interpreted these obligations, and that CFPB issued a bulletin on reasonable investigations in September 2013. CFPB stated that it has and will continue to communicate its expectations to CRAs regarding applicable provisions of FCRA. We maintain that providing additional information to CRAs about its expectations for key FCRA requirements could help CFPB to promote consistency and transparency in its supervisory approach and that the recommendation should be addressed.
Private Student Loans: Clarification from CFPB Could Help Ensure More Consistent Opportunities and Treatment for Borrowers
GAO-19-430, May 24, 2019
Director: Alicia Puente Cackley
Phone: (202) 512-8678

2 open recommendations
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Recommendation: The Director of CFPB should provide written clarification to nonbank private student loan lenders on their authorities under the Fair Credit Reporting Act to offer private student loan rehabilitation programs that include removing information from credit reports. (Recommendation 1)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: As of November 2019, CFBP does not plan to act on this recommendation because the law does not require nonbank private student loan lenders to seek CFPB's approval of student loan rehabilitation programs. CFPB stated that if a financial institution chooses to offer a private student loan rehabilitation program it would be protected under the Fair Credit Reporting Act. We maintain that clarification from CFPB that nonbank lenders have the authority to offer these programs could--depending on CFPB's interpretation--result in additional lenders offering rehabilitation programs that would allow more borrowers the opportunity to participate, or it could help ensure that only those entities CFPB has interpreted as being eligible to offer programs are doing so.
Recommendation: The Director of CFPB, after consulting with the prudential regulators and relevant industry groups, should provide written clarification on what information in a consumer's credit report constitutes a private student loan reported "default" that may be removed after successful completion of a private student loan rehabilitation program. (Recommendation 2)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: As of November 2019, CFPB stated that action on this recommendation is premature pending ongoing work by an industry association on what information may be removed from a credit report after successful completion of a private student loan rehabilitation program. We will continue to follow up with CFPB on its monitoring of this effort and consultation with relevant regulators.
Export-Import Bank: EXIM Should Explore Using Available Data to Identify Applicants with Delinquent Federal Debt
GAO-19-337, May 23, 2019
Director: Seto J. Bagdoyan
Phone: (202) 512-6722

2 open recommendations
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Recommendation: EXIM's chief operating officer should direct EXIM's Credit Review and Compliance Division to assess and document the practicality of incorporating into its preauthorization Character, Reputational, and Transaction Integrity (CRTI) reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants, and, if practical, implement relevant approaches—such as manual searches or batch matching. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In June 2020, we met with EXIM to discuss its efforts to assess the practicality of incorporating into its preauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants. Prior to the discussion, EXIM provided some information on its efforts. As part of the June 2020 discussion, we requested that EXIM provide additional information on its assessment. EXIM agreed to do so. We will provide an update on the status of this recommendation when we confirm what actions EXIM has taken in response to this recommendation.
Recommendation: EXIM's chief operating officer should direct EXIM's Credit Review and Compliance Division to assess and document the practicality of incorporating into its postauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants and participants, and, if practical, implement relevant approaches—such as manual searches or batch matching. (Recommendation 2)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In June 2020, we met with EXIM to discuss its efforts to assess the practicality of incorporating into its postauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants and participants. Prior to the discussion, EXIM provided some information on its efforts. As part of the June 2020 discussion, we requested that EXIM provide additional information on its assessment. EXIM agreed to do so. We will provide an update on the status of this recommendation when we confirm what actions EXIM has taken in response to this recommendation.
Export-Import Bank: Enhancements Needed in Credit Program Underwriting Policies and Procedures
GAO-19-43, May 14, 2019
Director: James R. Dalkin
Phone: (202) 512-3133

2 open recommendations
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Recommendation: The Chief Operating Officer of EXIM should consider establishing documented policies and procedures for (1) determining medium-term delegated authority lenders' eligibility for continued participation in EXIM's programs and (2) decertifying or taking other appropriate actions for such lenders that do not meet compliance or eligibility standards. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: EXIM concurred with our recommendation and stated that it will consider establishing documented policies and procedures for determining medium-term delegated authority lenders' eligibility for continued participation in EXIM's programs and decertifying or taking other appropriate actions for such lenders that do not meet compliance or eligibility standards. If implemented effectively, EXIM's planned actions should address the intent of our recommendation. An EXIM official indicated that actions to address this recommendation would be completed during 2020.
Recommendation: The Chief Operating Officer of EXIM should establish documented policies and procedures for periodically reviewing credit programs in which the government bears more than 80 percent of any loss to determine whether private sector lenders should bear a greater share of the risk. (Recommendation 2)

Agency: Export-Import Bank of the United States
Status: Open

Comments: EXIM concurred with this recommendation and stated that it will establish documented policies and procedures for periodically reviewing credit programs in which the government bears more than 80 percent of any loss to determine whether private sector lenders should bear a greater share of the risk. If implemented effectively, EXIM's planned actions should address the intent of our recommendation. An EXIM official indicated that actions to address this recommendation would be completed during 2020.