The new Direct Dispute Rules allow us to identify an address for direct disputes to be sent that is provided to a consumer. So, do we need to send out a notice to all consumers to accomplish this?

How are other banks addressing this provision. In reality, we would investigate all disputes, but would direct the disputes to be sent to a specific address to decrease the liability of possible violations.

I think that portion refers to having a correct address on file with the CRAs for your institution. Our direct dispute policy states you can submit a dispute at any of our locations. The disputes are processed at a specific location, but the consumer is not required to submit the dispute to that exact location.

We have in our policy that written disputes must be submitted to the main office. However, if a customer drops off the dispute at any branch office, it will be forwarded to the main office.

Maybe a silly question...my thinking is our bank should have direct dispute forms available for customers who inquire about such disputes. Is that as simple as it is, or must we somehow "provide" ALL our customers with this form?

You can do it however you want - there is no requirement to provide a direct dispute form to customers.

Thanks.

This is what we are doing as well.

Are you folks requiring the written dispute to be on a bank form, or simply be written. Currently allw e ask is that the dispute be written, and accompanied with a copy of the credit report showing the item they are disputing.

That's what we are doing as well.

The final rule requires written notification to consumers of a direct dispute address. I took this to mean that we had the choice to send a notice or post a notice in the lobby to provide written notification of the address. I was hoping someone had some language for the notice (other than the obvious of providing our Main Office address). Does anyone have something ready?

Where does it say that? Can't find it. Do you have a citation address?

This is all I find.....

(c) Direct dispute address. A furnisher is required to investigate a direct dispute only if a consumer submits a dispute notice to the furnisher at:
(1) The address of a furnisher provided by a furnisher and set forth on a consumer report relating to the consumer;
(2) An address clearly and conspicuously specified by the furnisher for submitting direct disputes that is provided to the consumer in writing or electronically (if the consumer has agreed to the electronic delivery of information from the furnisher); or
(3) Any business address of the furnisher if the furnisher has not so specified and provided an address for submitting direct disputes under paragraphs (c)(1) or (2) of this section.

We intend for our method to be...if a consumer contacts the bank (via any media and at any branch location) with a dispute, the consumer will be provided with a dispute form, in person, by mail or email (consumer's choice). We will not accept disputes by phone (by entering the information on a dispute form on the customer's behalf), or in any written form outside of our standard dispute form. The dispute form contains the "specified address" but we'll answer the claim as long as it is delivered by mail or in person to any of our branch locations, who will forward the form to the specified location. We do not intend to post the "specified address" or an other information about direct disputes in our lobbies, on our website, or via any other means.