Comptroller Dugan Supports FACT Act Implementation Rule
To Help Consumers Resolve Disputes with Financial Institutions

I would like to begin by noting my support for this proposal and thanking the staffs of all the agencies for their hard work in bringing forward this proposal for action at this time. This is the last of several significant FACT Act rulemakings, and the section 312 rulemaking will implement some very important consumer protections in that law.

The proposed rule sets forth two alternatives for defining the key terms “accuracy” and “integrity” – the characteristics we want to see in the information furnished to credit bureaus and other consumer reporting agencies. These alternatives provide a useful framework for public comment, and I fully expect that the public comment process will help us identify the best approach for ensuring that these provisions are implemented in a way that serves the interests of both consumers and users of consumer reports and is feasible for the entities that furnish consumer information to consumer reporting agencies.

The proposed rule on direct disputes would go a long way toward achieving something that I believe is critically important: making it easier for consumers to resolve disputes they have with their financial institutions. The proposal would essentially allow consumers to dispute – directly with the furnisher of the information – the accuracy of any information about the consumer’s account or performance that the furnisher provides to a consumer reporting agency.

Last Friday, I signed the proposed rule in my capacity as Comptroller of the Currency, and I will vote to approve the FDIC’s proposal today. The proposal is being published with a 60-day comment period, and I look forward to moving this forward to a final rule as quickly as possible after we complete our review of the comments.