FCRA Data Furnishing & Accuracy Requirements 2 — Questions and Answers
Question 1: Under the FCRA's 'Duty to Provide Accurate Information' standard, a furnisher violates the law if it reports information it knows or has reasonable cause to believe is:
- Older than seven years
- Inaccurate (Correct answer)
- Related to medical debt
- Derived from a soft inquiry
Correct answer: Inaccurate
Section 623(a)(1) prohibits furnishers from reporting information they know or have reasonable cause to believe is inaccurate.
Question 2: When a consumer disputes the completeness of a tradeline directly with a furnisher, the furnisher must conduct a reasonable investigation within how many days?
- 15 days
- 30 days (Correct answer)
- 45 days
- 60 days
Correct answer: 30 days
Section 623(b) requires furnishers to complete their investigation of a direct dispute within 30 days of receiving the notice.
Question 3: A furnisher discovers an account was reported with an incorrect charge-off date. Under the FCRA, the furnisher's FIRST obligation is to:
- Delete the tradeline immediately
- Notify all CRAs to block the entry
- Promptly notify each CRA of the correction (Correct answer)
- Wait for a consumer dispute before acting
Correct answer: Promptly notify each CRA of the correction
Section 623(a)(2) requires furnishers to promptly notify CRAs of corrections when they determine previously furnished information was inaccurate.
Question 4: Which regulatory body has primary authority to examine large non-bank furnishers (e.g., large debt collectors) for FCRA furnisher compliance?
- Federal Trade Commission
- Consumer Financial Protection Bureau (Correct answer)
- Office of the Comptroller of the Currency
- Federal Reserve Board
Correct answer: Consumer Financial Protection Bureau
The CFPB has supervisory and enforcement authority over large non-bank covered persons, including debt collectors acting as furnishers.
Question 5: The FCRA Furnisher Rule (Regulation V) defines a 'direct dispute' as one submitted by a consumer to the furnisher concerning:
- A dispute sent via certified mail only
- The accuracy or completeness of information in the consumer's file at a CRA (Correct answer)
- An oral complaint made by phone
- A dispute filed exclusively through the CFPB portal
Correct answer: The accuracy or completeness of information in the consumer's file at a CRA
Regulation V defines a direct dispute as one challenging the accuracy or completeness of information the furnisher provided to a CRA.
Question 6: A furnisher that receives a dispute notice from a CRA must report the results of its investigation back to the CRA. If the furnisher finds the information was inaccurate, it must:
- Report the correction only to the disputing CRA
- Report the correction to all CRAs to which it furnished the inaccurate data (Correct answer)
- Notify the consumer directly and take no further action
- Submit a correction only if the error affected the consumer's score by 10+ points
Correct answer: Report the correction to all CRAs to which it furnished the inaccurate data
After finding inaccuracy, a furnisher must correct and update the information at every CRA that received the flawed data, not just the one that initiated the dispute.
Question 7: Which of the following activities is explicitly EXEMPT from the FCRA's direct dispute requirements for furnishers?
- Disputes about payment history
- Disputes about a clerical address error on the account
- Disputes solely about the consumer's credit score calculation (Correct answer)
- Disputes about account ownership
Correct answer: Disputes solely about the consumer's credit score calculation
The Furnisher Rule exempts disputes that relate solely to the consumer's credit score or credit rating from the direct dispute process.
FCRA Data Furnishing & Accuracy Requirements 2
Under the FCRA's 'Duty to Provide Accurate Information' standard, a furnisher violates the law if it reports information it knows or has reasonable cause to believe is: