We just had a system update in mid-June and now our provider informs us that since the update, there might be an error in the credit reporting files. The result of the situation would be that the consumer has more beneficial credit bureau reporting information submitted than he is entitled to. For example if a customer was past due at the time the file was created, the 24 month payment history changed to a current status etc.
I believe we need to inform the credit bureaus that information reported in the last 3-4 months was inaccurate.
Do we also need to notify customers? I did not find any guidance in the regulations. I think we should, because if they had a report pulled during the period, it is misleading and we would have to face irate customers after the fix is made.
Do you think I need legal opinion on this?

This is a really interesting question that the FCRA does not answer. There are two ways to approach this. One is the customer service approach that you describe so that the customer would be aware of the problem. The other way of looking at this is to apply the information correction process. Just as you would if the consumer filed with you or the credit bureau claiming that information was incorrect, you would investigate, correct, and re-report the corrected information. In this situation, you self-discovered the error and corrected it. Under FCRA, it would appear that the rest is up to the credit bureau.