From Section 312:
(8) ABILITY OF CONSUMER TO DISPUTE INFORMATION DIRECTLY WITH FURNISHER —
`(A) IN GENERAL — The Federal banking agencies, the National Credit Union Administration, and the Commission shall jointly prescribe regulations that shall identify the circumstances under which a furnisher shall be required to reinvestigate a dispute concerning the accuracy of information contained in a consumer report on the consumer, based on a direct request of a consumer.
Until the final regs are issued we are not certain what type of disputes will be allowed directly with the "furnisher". It is speculated the disputes will be limited only to ones dealing with the specific "furnisher". But until we get the reg. we can't really "clarify" anything at this point (or at least I can't).
The opinions expressed are mine and they are not to be taken as legal advice.