CFPB Orders TD Bank to Pay $28 Million Over Systematic Credit Reporting Failures

The Consumer Financial Protection Bureau has ordered TD Bank to pay a total of $28 million following findings that the bank systematically failed to furnish accurate credit information to consumer reporting agencies and did not properly investigate consumer disputes about inaccurate entries. The enforcement action, announced on 11 September 2024, includes $7.76 million in redress directed to affected consumers and a $20 million civil money penalty.

The CFPB found that TD Bank violated the Fair Credit Reporting Act and Regulation V, the federal framework that governs how financial institutions report consumer credit data to bureaux such as Equifax, Experian, and TransUnion, and how they must respond when consumers challenge the accuracy of reported information.

DISPUTE INVESTIGATIONS

Central to the CFPB's enforcement action was TD Bank's handling of consumer disputes. When a consumer contacts their bank to challenge an inaccuracy in their credit file — a wrong account status, an erroneous payment record, or a debt that does not belong to them — the FCRA requires the furnisher to conduct a reasonable investigation and report corrected information to the bureau promptly. The CFPB found that TD Bank failed to conduct reasonable investigations, and that in some instances the bank conducted no investigation at all.

The CFPB's order requires TD Bank to pay $7.76 million in redress to affected consumers.

TD Bank is one of the ten largest banks in the United States by assets and operates an extensive consumer banking network primarily along the East Coast, with more than 1,200 branches serving customers with credit cards and deposit accounts.

REMEDIATION REQUIREMENTS

Under the CFPB's order, TD Bank is required to implement improvements to its credit furnishing and dispute resolution systems. The $20 million civil money penalty is payable to the CFPB's victims relief fund. CFPB Director Rohit Chopra said regulators would need to focus major attention on TD Bank to change its course.