Looking for insight Indirect Disputes. My understanding is that Frivolous disputes are not weeded out at the bureau, but instead can be grouped into case management for reference - is this correct? Therefore, issuers would expect to see Frivolous disputes in the Indirect dispute population.

How would a regulator view the following scenario: Indirect Dispute is received & furnisher meets the requirements by responding to the Indirect dispute via ACDV within the requested timeframe, AND IN ADDITION, furnisher also sends a letter to the consumer, stating their dispute is Frivolous? Could this viewed as a Reg violation?