← B2BB2B · COMPLIANCEFurnisher data audit
Furnisher data audit
before the regulator looks.
Banks, neobanks, BNPL, and any entity reporting to CRAs is a §1681s-2 furnisher. Your reporting flow has errors you haven't seen yet — errors that become $500M CFPB consent decrees. We audit your data before it leaves your stack.
What we audit
- ◆Furnisher file integrity (Metro 2, e-OSCAR) before submission
- ◆Pattern detection: accidental re-aging across your portfolio
- ◆Post-dispute reinvestigation completeness (FCRA §1681s-2(b))
- ◆Consistency between your core system + bureau submission
- ◆Cross-bureau variance in what you report for same consumer
Deliverables
- ◆Pre-submission anomaly dashboard — fix before harm
- ◆SHA-3 sealed snapshot of every reporting cycle (legal defense)
- ◆Monthly compliance attestation (SOC 2 / NYDFS / OSFI ready)
- ◆CFPB/AG investigation toolkit — 24h to produce chain of custody
- ◆Audit trail admissible in regulatory + civil actions
Enforcement context (2024-2026)
- ◆CFPB $100M against a top 5 BNPL for §1681i/s-2 pattern violations
- ◆$250M multi-state AG action against fintech aggregator
- ◆OSFI updated guidance on Canadian furnisher accuracy
- ◆EU DORA compliance layer (ICT risk + outsourcing of credit data)
- ◆Your reporting volume is your liability surface
Integration
- ◆REST API: ingest furnisher files via your existing workflow
- ◆Inline pre-submission: Credit Truth scores → your system holds/releases
- ◆SaaS dashboard for compliance officers
- ◆SOC/SOX attestation reports quarterly
- ◆White-glove onboarding for enterprise accounts