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Credit reporting under the FCRA during COVID-19

Posted on May 5, 2020 by Sheri Lash

The undersigned Attorneys General of New York, Pennsylvania, California, Colorado, Delaware, Hawaii, Illinois, Iowa, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, North Carolina, Rhode Island, Virginia, Washington, Wisconsin and the District of Columbia wrote a letter to remind the consumer reporting agencies (“CRAs”) of their continuing obligation during the COVID-19 crisis to comply with the protections contained in the Fair Credit Reporting Act (“FCRA”); state laws governing credit reporting; and offices’ agreements with the CRAs.

Under section 611 of the FCRA, it states if the completeness or accuracy of any item of information contained in a consumer’s file at a consumer reporting agency is disputed by the consumer and the consumer notifies the agency directly, or indirectly through a reseller, of such dispute, the agency shall, free of charge, conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate and record the current status of the disputed information or delete the item from the file in accordance with paragraph (5), before the end of the 30-day period beginning on the date on which the agency receives the notice of the dispute from the consumer or reseller. The 30-day period described may be extended for not more than 15 additional days if the consumer reporting agency receives information from the consumer during that 30-day period that is relevant to the reinvestigation.

Bottom Line Screening along with our partners are keeping disputes within the allowed time frame under FCRA, complying with all provisions of the FCRA and state law requirements. Our percentage of disputed files is 0.04% and are taken care of as follows:

 Within five business days of the date we receive notice of the consumer dispute from the consumer, we start a reasonable reinvestigation to determine whether the dispute is related to an action or omission.

 Within 30 days reinvestigate, correct, and/or delete disputed information.

 Extend the reinvestigation 15 calendar days if the consumer provides additional information after the initial dispute notification.

 Within five business days notify any data furnisher of receipt of the consumer dispute by using the “Notice to Data Furnisher of Reinvestigation of Consumer Dispute”. Forward all documentation the consumer has provided to you to the source. Do not paraphrase or “categorize” the dispute, just forward the facts.

 Docket a follow-up date with furnishers 5 to 7 business days prior to the end of the investigation period to ensure that you conclude the matter within the time allowed.

 If a consumer requests a description of the procedure used to determine the accuracy and completeness of the information, we have 15 calendar days after receiving the request to respond.

 If deleted information is eventually found to be complete and accurate and is reinserted in the file, the consumer must be notified in writing no later than 5 business days after the reinsertion.

This is a challenging time as many individuals’ credit reports will be affected by COVID-19, and BLS is committed to complying with FCRA regulations now and in the future. Any further questions, please feel free to reach out to us and we will be happy to assist.

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Bottom Line Screening
South Haven, Michigan 49090

Office: 269-214-0697
info@BottomLineScreening.com

Hours of Operation: Monday - Friday 9am - 5pm

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Contact Us

Bottom Line Screening
South Haven, Michigan 49090

Office: 269-214-0697
info@BottomLineScreening.com

Hours of Operation: Monday - Friday 9am - 5pm

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