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Violations Identified
Credit card furnishers failed to conduct any investigations of disputes received from CRCs or send results of dispute investigations to the CRCs due to furnishing system implementation issues . They also failed to conduct reasonable investigation of disputes due to erroneously calling thousands of indirect disputes frivolous .
Auto furnishers failed to conduct reasonable investigations of disputes received by CRCs . Furnishers incorrectly calculated consumers ’ payment histories while processing dispute investigations , resulting in the furnishers including incorrect payment histories in the dispute results reported to the CRCs .
Violation Reasoning
The FCRA requires furnishers to complete their investigations of direct disputes received from consumers and report the results before the expiration of the time period that would have been required for the CRC to complete its investigation had the consumer sent the dispute to the CRC instead of the furnisher . Examiners found the furnishers conducted investigations of direct disputes and sent the consumers response letters , but the letters failed to communicate results of the investigations . The letters failed to provide consumers with results of dispute investigations because they did not affirmatively inform the consumers changes were made in response to disputes .
The FCRA requires when a furnisher determines information furnished to CRCs is not complete or accurate , the furnisher must “ promptly ” notify the CRC of that determination and provide any corrections to that information , or any additional information , necessary to make the information provided by the furnisher to the CRC complete and accurate . After determining information furnished to CRCs is not complete or accurate , furnishers must also stop furnishing to CRCs information that remains not complete or accurate . Examiners found furnishers failed to send updated or corrected information to CRCs after deciding information the furnishers had reported was not complete or accurate . Additionally , they also found credit card furnishers failed to promptly update account statuses to settledin-full , paid-in-full , voluntarily closed , or discharged in bankruptcy upon recognizing the account statuses furnished did not match the account statuses in the furnishers ’ systems of record .
Regulation V , the implementing regulation to FCRA , requires furnishers to establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information relating to consumers furnished to a CRC . The policies and procedures must
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