FCRA Consumer Rights & Dispute Resolution 5 — Questions and Answers
Question 1: A consumer requests their credit score from a CRA under FCRA §609(f). Which of the following must the CRA include with the score disclosure?
- Only the numerical score
- The score, key factors, the range, the date, the name of the entity that provided the score, and contact info (Correct answer)
- The score and the names of all creditors who contributed to it
- The score and a prediction of future creditworthiness
Correct answer: The score, key factors, the range, the date, the name of the entity that provided the score, and contact info
Under §609(f), credit score disclosures must include the score, up to 4 key factors, the range of scores, the date the score was created, the entity providing the score, and contact information.
Question 2: Which of the following best describes a 'security freeze' under the FCRA?
- A temporary 90-day restriction placed by a CRA on a delinquent account
- A prohibition that restricts a CRA from releasing a consumer's credit report without the consumer's authorization (Correct answer)
- A court order freezing all credit card accounts pending fraud investigation
- A furnisher's right to stop reporting during dispute reinvestigation
Correct answer: A prohibition that restricts a CRA from releasing a consumer's credit report without the consumer's authorization
A security freeze prohibits the CRA from releasing a consumer's credit report to third parties (e.g., new creditors) without the consumer first lifting or temporarily thawing the freeze.
Question 3: Under the Economic Growth Act amendments to the FCRA, how quickly must a nationwide CRA place a security freeze after receiving a consumer's request?
- 1 business day for electronic requests, 3 business days for mail (Correct answer)
- 3 business days for all requests
- Immediately for electronic/phone requests, 5 business days for mail
- 5 business days regardless of the request method
Correct answer: 1 business day for electronic requests, 3 business days for mail
After EGRRCPA amendments, CRAs must place security freezes within 1 business day of an electronic or phone request, and within 3 business days of a mail request.
Question 4: A consumer submits a dispute statement of 100 words to a CRA after an unsuccessful reinvestigation. What must the CRA do with this statement?
- Include it in all future disclosures of the consumer's file (Correct answer)
- Forward it to the CFPB for review
- Send it only to the furnisher involved in the dispute
- Hold it for 30 days and then discard it
Correct answer: Include it in all future disclosures of the consumer's file
The CRA must include the consumer's dispute statement in all future file disclosures and, when feasible, in credit reports provided to users.
Question 5: Which entity has primary rulemaking authority over the FCRA for most consumer reporting matters following the Dodd-Frank Act?
- Federal Trade Commission (FTC)
- Consumer Financial Protection Bureau (CFPB) (Correct answer)
- Office of the Comptroller of the Currency (OCC)
- Federal Reserve Board
Correct answer: Consumer Financial Protection Bureau (CFPB)
The Dodd-Frank Act transferred primary FCRA rulemaking authority to the CFPB, though the FTC retains some enforcement authority.
Question 6: A consumer who is unemployed and seeking employment within 60 days requests a free file disclosure from a CRA. How many free disclosures per 12-month period is this consumer entitled to under the FCRA?
- One, same as any other consumer
- Two (Correct answer)
- Three
- Unlimited during the job-search period
Correct answer: Two
Under FCRA §612(b), unemployed consumers who are seeking employment within 60 days, welfare recipients, and victims of identity theft are entitled to an additional free disclosure, for a total of two per 12-month period.
Question 7: A creditor takes adverse action based on a credit report and sends the required adverse action notice. Which of the following is NOT a required element of that notice under FCRA §615?
- The name, address, and phone number of the CRA that supplied the report
- A statement that the CRA did not make the credit decision
- The consumer's specific credit score and the exact reason for denial (Correct answer)
- A statement that the consumer has the right to obtain a free report and dispute inaccuracies
Correct answer: The consumer's specific credit score and the exact reason for denial
Adverse action notices must identify the CRA and disclaim the CRA's role in the decision, and inform consumers of their right to a free report and dispute rights — but there is no requirement to disclose the specific credit score used or give the exact reason for denial in the FCRA adverse action notice itself.
FCRA Consumer Rights & Dispute Resolution 5
A consumer requests their credit score from a CRA under FCRA §609(f).
Which of the following must the CRA include with the score disclosure?