Testimony of Veneshia Ferdinand on Promoting Access to Credit

Chairman Barr, Ranking Member Foster, and Members of the Subcommittee, thank you for the opportunity to testify on behalf of the American Bankers Association (ABA) at today's hearing entitled: "Promoting Access to Credit for Everyday Americans." I am Veneshia Ferdinand, and I serve as Assistant Vice President and Director of Compliance Policy at Simmons Bank, which is a subsidiary of Simmons First National Corporation, headquartered in Pine Bluff, Arkansas. Simmons Bank operates over 220 branches throughout the Mid-South in Arkansas, Kansas, Missouri, Oklahoma, Tennessee, and Texas.

I have over 24 years of experience in banking and financial services, with a strong focus on consumer credit reporting, federal consumer protection laws, and operational compliance under the Fair Credit Reporting Act (FCRA). In my testimony, I will focus on how the FCRA operates in practice and how regulatory policy impacts consumers, data furnishers, and financial institutions. My testimony will cover three key points:

• Banks are important participants in the credit reporting system and work hard to ensure they are living up to their consumer protection obligations and providing the best customer experience they can.
• The more complete and accurate information in the credit reporting system, the better banks can manage risk and responsibly meet consumers’ credit needs.
• Even well-intended policy changes can unintentionally increase costs and introduce process challenges that affect credit reporting accuracy and risk management, which ultimately impact credit availability.

Overview of the Credit Reporting Framework

The Fair Credit Reporting Act and its implementing regulation, Regulation V, establish the legal framework governing the collection, furnishing, use, and disclosure of consumer credit information in the United States. The FCRA and Regulation V assign rights and obligations to four primary participants in the credit reporting system: consumers, consumer reporting agencies, furnishers of information in consumer reports, and users of consumer reports. Financial institutions often operate as users and furnishers simultaneously, placing them at the center of the credit reporting ecosystem.

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