Credit Dispute Checklist
by Andy Zavoina, BOL Guru Guru BIOS
Question: An FDIC examiner suggested that the bank develop a written procedure for responding in a timely fashion to consumer disputes concerning credit report information. Is there such a checklist available outlining steps in response to a credit dispute?
Answer: I haven't seen such a list, but it isn't a bad idea. Refer to the FCRA §611. You could receive a dispute from a credit bureau, or directly from the consumer.
You have 30 days to:
Investigate the disputed information for accuracy
Review all the relevant information, not just your internal records as an example
Respond to the credit reporting agency with the results
Correct the erroneous information with this credit reporting agency and all other nationwide agencies you provided the data to.
If the dispute is from a consumer directly, they would also be notified in the process above.
Reports to the bureau during the investigation period should indicate it is disputed.
In Johnson v. MBNA the Fourth Circuit held that MBNA did not do a complete investigation. MBNA researched its own computerized records and no other. The jury awarded the plaintiff $90,300.
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