Our understanding is that a Bank can be a "User" of credit bureau information and not a "Furnisher."

Would like to know what other banks are doing - and the pros/cons of NOT furnishing consumer credit information.

We don't furnish.

Our portfolio of non-commercial loans is so small it's not worth it for us.

At my bank:

We are a user when we pull credit reports from the credit bureau.

We are a furnisher when we report current/past due loans to the credit bureau.

If you do not furnish information your borrowers cannot build a credit history. For some that would be good, but for others it would make life difficult when they are doing simple things like getting utility services.

A good credit history is a basic building block for living in today's world.

Good point Ken. Not furnishing information was one of the secrets of predatory lenders. The 'bad credit' customer would get a loan, then eventually make all payments as agreed. The predatory lenders would not share the paid as agreed with the credit bureaus, and their reported credit never changed. That was brought up in one of the OCC's early bulletins describing predatory lenders 2001-6.

"The term “subprime” refers to the credit characteristics of individual borrowers.
Subprime borrowers typically have weakened credit histories that include payment delinquencies, and possibly more severe problems such as charge-offs, judgments, and bankruptcies. They may also display reduced repayment capacity as measured by credit scores, debt-to-income ratios, or other criteria that may encompass borrowers with incomplete credit histories." (Emphasis added.)

Has anyone received Regulator criticism for NOT furnishing information to the consumer reporting agencies?

In many cases, reporting is part of the contract with the CRA - they provide the reports, and the creditor has to supply the historical payment information in return. This way, they are ensured of having correct file information.