Background

The Fair Credit Reporting Act (FCRA) encourages but does not require financial institutions to provide consumer information to credit reporting agencies. If an institution decides to furnish information to a agencies, the FCRA and Regulation V (which implements the FCRA) require the institution to "establish and implement reasonable written policies and procedures concerning the accuracy and integrity of the information it furnishes to consumer reporting agencies." 12 C.F.R. §1022.42. See also, CFPB Bulletin 2016-01.

Institutions are required to maintain the accuracy of information that is reported by investigating consumer disputes. Within 30 days after receiving a direct dispute notice, you must review all relevant information provided by the consumer, conduct a reasonable investigation of the dispute, and report the results of the investigation to the consumer. If the investigation finds that information reported was inaccurate, you must then “promptly notify” each CRA of the inaccurate determination and provide them with the necessary corrections to ensure the accuracy of the information. 12 C.F.R. §1022.43(e).

Usage

To comply with this requirement, this user override will display the following questions to fulfillment users on the Summary tab during intake when the account type is Credit Card.

• Is this claim related to a credit bureau reporting dispute?
  • Yes
    • Was the dispute received in writing from the consumer or from a credit reporting agency?
      • Yes
      • No
  • No

If the answer to both questions is "Yes", the Regulation Z SLA will be overridden by the FCRA SLA, which requires the claim to be resolved within 30 days, instead of 2 full statement cycles.