CFPB Sets Dispute Resolution Expectations for Consumer Reporting Companies and "Information Furnishers"

The CFPB warned that, under the Fair Credit Reporting Act ("FCRA"), consumer reporting companies and the entities that furnish information to them cannot "impose obstacles that deter submission of disputes" and can be held liable for failing to investigate disputes.

In a Consumer Financial Protection Circular, the CFPB said that "enforcers may bring claims if consumer reporting agencies and furnishers limit consumers' dispute rights by requiring any specific format or requiring any specific attachment such as a copy of a police report or consumer report beyond what the statute and regulations permit." The CFPB said that consumer reporting agencies must provide to the furnisher all relevant information regarding the dispute that it received from the consumer. The CFPB recognized that electronic information sharing may pose additional challenges to FCRA compliance because reporting companies may not be able to provide information furnishers with all the original documentation related to a dispute.