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FDIC Federal Register Citations

From: Anonymous
Sent: Friday, May 19, 2006 9:29 AM
To: Comments

Subject: Interagency Advance Notice - (RIN- 064/AC99)

A furnisher should be required to investigate a dispute directly from a consumer. In fact, the rule should be that consumers should dispute information with the furnisher first. Having worked in a financial services operation in charge of credit bureau reporting and managing on line disputes from the credit reporting agencies, I can fully endorse the difficulties of the consumers and furnishers in attempting to accurately portray the credit information on file. It seems that consumers and furnishers are at the mercy of the credit reporting agencies.

Our corporation submits monthly updates with the most accurate and up to date information. This may also involve submitting a request to have the tradeline deleted in certain situations. Many times, we receive consumer initiated disputes from the bureaus on tradelines that are not supposed to be visible to the consumer. In addition, the dispute provided by the consumer reporting agencies on the web based dispute system is generic or totally dependent on the input of the credit reporting agency. The furnisher is not provided any documentation to support the dispute and cannot do a thorough investigation of any kind. If the consumer contacted us directly, we would be able to accurately identify legitimate disputes and request the appropriate documentation to investigate. This is especially true iin cases of Identity theft disputes. The Fact Act places many requirements on furnishers who are notified of an identity theft dispute from the credit reporting agencies without providing guidance on how we can investigate internally to determine if the dispute is legitimate.

Of course there would be increased costs to the furnishers initially, however in the long run it would decrease multiple disputes received from each bureau. The time frames could also pose a problem because in many instances, a dispute cannot be resolved in one contact with the consumer. We may require additional information or documentation in order to properly investigate or to aid in determining if the dispute is frivolous.

No Name Please

 


Last Updated 05/22/2006 Regs@fdic.gov

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