Understood, but I am being asked to opine if we are REQUIRED to follow FCRA for a verbal direct dispute. It seems a strict reading of the rule is yes. In the past, I had thought it was only if a written request was submitted and the business was trained to advise the caller/person to put their request in writing to preserve their rights under the FCRA. Most customers did not take the time to put the dispute in writing, so bankers started following the FCRA for verbal disputes. Now, someone is asking if that is required. It seems it might be. Do you (or does anyone) agree?
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