FCRA Data Furnishing & Accuracy Requirements 4 — Questions and Answers
Question 1: Which Metro 2 'Account Status Code' should a furnisher report for an account that is current and has never been late?
- 11 (Current) (Correct answer)
- 05 (Transferred)
- 13 (Paid)
- 97 (Unpaid after charge-off)
Correct answer: 11 (Current)
Metro 2 Account Status Code 11 designates an account that is current and in good standing with no delinquency.
Question 2: A consumer sends a written direct dispute to a furnisher but fails to include any supporting documentation. What should the furnisher do?
- Automatically deem the dispute frivolous due to lack of documentation
- Investigate the dispute using its own records before seeking additional information (Correct answer)
- Forward the dispute immediately to all three CRAs
- Suspend the account pending receipt of documentation
Correct answer: Investigate the dispute using its own records before seeking additional information
A furnisher must investigate using records it already has; demanding documentation before investigating is not permitted unless the dispute is genuinely unintelligible.
Question 3: Re-aging a delinquent account — resetting the original delinquency date to make it appear more recent — violates which specific FCRA provision?
- Section 604 (permissible purpose)
- Section 605 (obsolescence/reporting period) (Correct answer)
- Section 615 (adverse action)
- Section 621 (administrative enforcement)
Correct answer: Section 605 (obsolescence/reporting period)
Re-aging manipulates the delinquency date to extend a negative item's reporting window, directly violating Section 605's 7-year obsolescence limit.
Question 4: A furnisher that voluntarily furnishes information to CRAs (and is not required by law to do so) is still subject to FCRA Section 623 accuracy requirements. This is because:
- Voluntary furnishing is prohibited without a CRA contract
- The FCRA applies to all furnishers regardless of whether furnishing is mandatory or voluntary (Correct answer)
- Voluntary furnishers are only subject to state law obligations
- CRAs assume liability on behalf of voluntary furnishers
Correct answer: The FCRA applies to all furnishers regardless of whether furnishing is mandatory or voluntary
Section 623 applies to any person that furnishes information to a CRA, whether doing so is legally required or voluntary.
Question 5: Which of the following is a required element of a furnisher's written policies and procedures under Regulation V?
- Annual third-party audits of all CRA data files
- Guidelines for identifying and correcting inaccurate information before and after furnishing (Correct answer)
- Mandatory arbitration clauses for consumer disputes
- Biannual retraining of all customer service staff
Correct answer: Guidelines for identifying and correcting inaccurate information before and after furnishing
Regulation V requires furnishers to establish and implement reasonable written policies that include procedures for identifying and correcting inaccuracies both before and after submission to CRAs.
Question 6: A furnisher receives notice that a consumer has obtained an identity theft block on a tradeline. The furnisher subsequently re-reports that same account. What has the furnisher most likely violated?
- Section 605B — prohibition on re-reporting blocked information without meeting specific criteria (Correct answer)
- Section 604 — permissible purpose restriction
- Section 616 — civil liability for willful noncompliance only
- Section 623(b) — the dispute response timeline
Correct answer: Section 605B — prohibition on re-reporting blocked information without meeting specific criteria
Section 605B prohibits furnishers from re-reporting information that a CRA has blocked as identity theft unless the furnisher has reasonable grounds to believe the block was based on a material misrepresentation.
Question 7: In an E-OSCAR dispute workflow, what does the two-digit 'Image Indicator' field communicate to the furnisher?
- Whether the consumer's score improved after the prior dispute
- Whether document images supporting the consumer's dispute are attached (Correct answer)
- The number of prior disputes filed by the consumer
- The CRA's preliminary determination of dispute validity
Correct answer: Whether document images supporting the consumer's dispute are attached
The Image Indicator field in E-OSCAR tells the furnisher whether consumer-provided supporting documents accompany the ACDV transmission.
FCRA Data Furnishing & Accuracy Requirements 4
Which Metro 2 'Account Status Code' should a furnisher report for an account that is current and has never been late?