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Consumer credit reporting agencies (CCRAs) that reported on 1,000 or more New York consumers in any 12-month period between June 1, 2018, and Sept. 1, 2018, were required to register with the Department of Financial Services (DFS) Superintendent on or before Sept. 15. The underlying reasons, according to the DFS, include the failure of CCRAs to safeguard and maintain accurate consumer data and accurately investigate consumer disputes of alleged inaccuracies. Whether a consumer reporting agency qualifies as a CCRA that is required to register depends upon 1. Whether reports only contain criminal or non-credit information; whether the agency regularly engages in the practice of assembling or evaluating and maintaining credit information for the purposes of furnishing consumer reports; and whether the CRAs maintain credit account information from furnishers regularly in the ordinary cause of business.

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