Earlier this year we merged a smaller bank into ours. There was a loan of theirs that paid off in 2013. That borrower is now disputing the payment history of that paid off loan. Since this was prior to merger and the old bank doesn't report anymore, do we have any duties here? We didn't assume the old bank's subscriber number and nothing was reported under the remaining bank's number so I don't even know how we would change it.

In my opinion you are definitely required to respond. The borrower's right to Fair Credit Reporting by the small bank didn't die when it merged. Typically any bank merger agreement specifically details that the surviving institution will assume all debts, obligations and duties of the merging entity. I would contact my Credit Bureau rep to determine how you would go about responding to the dispute given the subscriber number issue.

Thanks for the response!