1 

Fair Credit Reporting Act

Efforts to Promote 

Consumer Report 

Accuracy and Disputes

A Report to Congress

Federal Trade Commission 

2020
 

 

 

 

 

 

 

 

 

Disputes and Accuracy Report | 2020 

I. INTRODUCTION 

This report responds to Senate Report 116-111, the Appropriations Committee’s report 

accompanying the Financial Services and General Government Appropriations Bill, 

2020, directing the Federal Trade Commission (“Commission” or “FTC”) to report on “its 

consumer education efforts with respect to disputing and correcting information in a 

credit report, as well as its enforcement efforts related to dispute processes and the 

correction of inaccurate and incomplete information.”1 The Federal Trade Commission 

appreciates this opportunity to provide this report. 

Congress enacted the Fair Credit 

Reporting Act2 (“FCRA”) in 1970, Errors in consumer reports, however, can 

recognizing the Congress enacted the cause consumers to be denied credit or 

Fair Credit Reporting Act3 (“FCRA”) in other benefits or pay a higher price for 1970, recognizing the importance of them. For this reason, accuracy of “fair and accurate credit reporting” to consumer reports is critically important. maintain “the efficiency of the banking 

system” and “the public[’]s confidence” 

in that system.4 Consumer reports are reports of information compiled on individual 

consumers that are used or expected to be used to determine eligibility for credit, 

insurance, employment, and other similar purposes. They often include consumer credit 

histories or public record information, such as arrests, convictions, judgments, and 

bankruptcies. These consumer reports are often used to evaluate the risk of future 

nonpayment, default, or other adverse events. Errors in consumer reports, however, 

can cause consumers to be denied credit or other benefits or pay a higher price for 

them. For this reason, accuracy of consumer reports is critically important. 

The FCRA imposes a number of obligations on those who compile and sell consumer 

reports—consumer reporting agencies (“CRAs”)—regarding consumer report accuracy 

and consumer disputes. CRAs must comply with requirements to help ensure the 

accuracy of consumer reports, including requirements that CRAs (1) maintain 

reasonable procedures to ensure the “maximum possible accuracy” of consumer 

reports5 and (2) maintain procedures through which consumers can dispute and correct 

inaccurate information in their consumer reports.6 In addition, the FCRA imposes 

obligations on those who furnish information about consumers to CRAs (“furnishers”), 

such as entities extending credit. For example, furnishers have a duty to establish and 

1 S. Rep. No. 116-111, at 72. 2 15 U.S.C. §§ 1681–1681x. 

3 15 U.S.C. §§ 1681–1681x. 

4 Id. § 1681(a). 

5 Id. § 1681e(b). 

6 Id. § 1681i(a)–(d)(1). 

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Disputes and Accuracy Report | 2020 

implement reasonable written policies and procedures regarding the accuracy and 

integrity of the information they report, report accurate information, and investigate 

consumer disputes of inaccurate information.7 Users of consumer reports have 

obligations under the statute as well. For example, if a user of a consumer report takes 

an adverse action against a consumer—such as a denial of credit or employment— 

based on information in a consumer report, the user must provide an adverse action 

notice to the consumer, which explains how the consumer can obtain a free copy of the 

report and dispute any inaccurate information in the report.8 

II. FTC ACTIVITIES TO PROMOTE CREDIT REPORT ACCURACY 

The Commission has played a key role in the implementation, enforcement, and 

interpretation of the FCRA since its enactment.9 As the consumer reporting system 

evolves and new technologies and business practices emerge, consumer and business 

education concerning applicable rights and responsibilities under the FCRA, as well as 

vigorous enforcement, continue to be top priorities for the Commission. 

A. Consumer and Business Education 

The FTC has a number of user-friendly resources for consumers designed to inform 

them of their rights under the FCRA and assist them with navigating the consumer 

reporting system, including the dispute process. The publication Credit and Your 

Consumer Rights provides an overview of credit, explains consumers’ legal rights, and 

offers practical tips to help solve credit problems.10 Additionally, the publication 

Disputing Errors on Credit Reports explains how consumers can obtain their credit 

report and dispute inaccurate information, including sample dispute letters.11 The FTC 

also has publications that explain how consumers can obtain their free annual credit 

reports from each of the nationwide consumer reporting agencies,12 as well as navigate 

7 12 C.F.R. §§ 1022.42–.43; 15 U.S.C. § 1681s-2(a)–(b). 

8 15 U.S.C. § 1681m(a). The adverse action notice also must include a statement that the CRA that 

supplied the consumer report did not make the decision to take the adverse action and cannot give the 

consumer any specific reasons for the decision. Id. § 1681m(a)(2)(B). 

9 As enacted, the FCRA established the Commission as the primary federal enforcement agency, with 

wide jurisdiction over entities involved in the consumer reporting system; the primary exceptions to the 

Commission’s jurisdiction are federally regulated financial institutions. See 15 U.S.C. § 1681s(a)–(b). 

Pursuant to the Consumer Financial Protection Act of 2010 (“CFPA”), Title X of Pub. L. No. 111-203, 124 

Stat. 1955 (July 21, 2010) (The Dodd-Frank Wall Street Reform and Consumer Protection Act), the 

Commission shares its FCRA enforcement role with the Consumer Financial Protection Bureau (“CFPB”) 

in many respects.

10 Credit and Your Consumer Rights (June 2017), https://www.consumer.ftc.gov/articles/0070-credit-andyour-consumer-rights. 11 Disputing Errors on Credit Reports (Feb. 2017), https://www.consumer.ftc.gov/articles/0151-disputingerrors-credit-reports. 12 Free Credit Reports (Mar. 2013), https://www.consumer.ftc.gov/articles/0155-free-credit-reports. 

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employment background checks13 and tenant background checks.14 The Commission 

periodically publishes blog posts reminding consumers about their rights and the FTC 

resources available to assist them and continues to update and expand its materials as 

new issues arise. For example, in January 2020, the FTC published a four-part blog 

series to help consumers manage credit, including discussions of (1) why does your 

credit matter; (2) getting your credit report; (3) reading your credit report; and (4) fixing 

your credit report.15 

The Commission has also created a dedicated 

website for identity theft victims, whose consumer IdentityTheft.gov is the federal 

reports may be riddled with inaccurate information government’s one-stop resource 

as a result of identity theft. IdentityTheft.gov is the for identity theft victims. 

federal government’s one-stop resource for 

identity theft victims. People can use 

IdentityTheft.gov to report identity theft to the Federal Trade Commission and get a 

step-by-step personal recovery plan.16 The site also creates an Identity Theft Report 

that victims can use to clear their credit files of fraudulent information resulting from the 

identity theft. IdentityTheft.gov has detailed advice for more than 30 types of identity 

theft and also is available in Spanish at RobodeIdentidad.gov. When people use 

IdentityTheft.gov, their report becomes part of the Consumer Sentinel Network17 

database and is available to the Network’s law enforcement members. 

In terms of business education, the FTC has published guidance for employment and 

tenant background screening companies regarding their obligations under the FCRA, 

including with respect to accuracy and consumer disputes.18 For furnishers, the FTC 

publication Consumer Reports: What Information Furnishers Need to Know provides an 

overview of furnisher obligations under the FCRA.

19 Similarly, for users of consumer 

reports, the FTC has published guidance for employers, land lords, insurers, and 

13 Background Checks (Mar. 2018), https://www.consumer.ftc.gov/articles/0157-background-checks. 14 Renting an apartment? Be prepared for a background check (Nov. 2016), 

https://www.consumer.ftc.gov/blog/2016/11/renting-apartment-be-prepared-background-check. 15 See, e.g., New year, new credit blog series (Jan. 2020), 

https://www.consumer.ftc.gov/blog/2020/01/new-year-new-credit-blog-series. 16 Since the inception of IdentityTheft.gov on January 22, 2016 through February 17, 2020, the site has 

received more than 1.9 million identity theft complaints from consumers.

17 The Consumer Sentinel Network provides law enforcement members with access to complaints 

provided directly to the Federal Trade Commission by consumers, as well as providing members with 

access to complaints shared by data contributors, such as governmental agencies and other 

organizations.

18 See What Employment Background Screening Companies Need to Know About the Fair Credit 

Reporting Act (Apr. 2016), https://www.ftc.gov/tips-advice/business-center/guidance/what-employmentbackground-screening-companies-need-know-about; What Tenant Background Screening Companies 

Need to Know About the Fair Credit Reporting Act (Oct. 2016), https://www.ftc.gov/tips-advice/businesscenter/guidance/what-tenant-background-screening-companies-need-know-about-fair. 19 See Consumer Reports: What Information Furnishers Need to Know (Nov. 2016), 

https://www.ftc.gov/tips-advice/business-center/guidance/consumer-reports-what-information-furnishersneed-know. 

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Disputes and Accuracy Report | 2020 

creditors describing their obligations under the FCRA, including providing adverse 

action notices to consumers.20 

Finally, each time it announces a new law enforcement action, the FTC typically 

publishes consumer and business blog posts describing the case and discussing 

lessons learned for businesses and consumers. For example, along with the 

announcement of a settlement with tenant background screening company RealPage,

21 

the Commission published a consumer blog post for consumers seeking housing and a 

business blog post with guidance for background screening companies.22 

Appendix A contains a more comprehensive list of the FTC’s consumer publications on 

disputing and correcting information in consumer reports. 

B. Law Enforcement 

In the last decade, the Commission has brought more than 30 actions to enforce the 

FCRA against consumer reporting agencies (“CRAs”), users of consumer reports, and 

furnishers of information to CRAs. Approximately half of those cases involve allegations 

related to processes for handling consumer disputes of inaccurate information or 

procedures for ensuring the accuracy of information in consumer reports. With the 

advent in 2011 of the CFPB’s supervisory authority over the nationwide consumer 

reporting agencies and the coordination efforts between the federal agencies, the FTC 

has focused its FCRA law enforcement efforts on other entities in the credit reporting 

area and other aspects of the consumer reporting industry more broadly. 

For example, the FTC settled cases against furnishers that allegedly had inadequate 

policies and procedures for reporting accurate credit information to CRAs and handling 

consumer disputes. In Credit Protection Association, LP, the Commission alleged that a 

debt collector failed to have adequate policies and procedures to handle consumer 

disputes, did not have a policy requiring notice to consumers of the outcomes of 

investigations about disputed information, and in numerous instances failed to inform 

20 See Consumer Reports: What Employers Need to Know (Oct. 2016), 

https://www.ftc.gov/tipsadvice/business-center/guidance/using-consumer-reports-what-employers-needknow; Consumer Reports: What Landlords Need to Know (Oct. 2016), https://www.ftc.gov/tipsadvice/business-center/guidance/usingconsumer-reports-what-landlords-need-know; Consumer Reports: 

What Insurers Need to Know (Nov. 2016), https://www.ftc.gov/tips-advice/businesscenter/guidance/consumer-reports-what-insurers-need-know; Using Consumer Reports for Credit 

Decisions: What to Know About Adverse Action and Risk-Based Pricing Notices (Nov. 2016), 

https://www.ftc.gov/tips-advice/business-center/guidance/using-consumer-reports-credit-decisions-whatknow-about-adverse. 21 FTC v. RealPage, Inc, No. 3:18-cv-02737-N (N.D. Tex. filed Oct. 16, 2018), 

https://www.ftc.gov/enforcement/cases-proceedings/152-3059/realpage-inc. 22 See, e.g., Will background check errors deny you a home? (Oct. 2018), 

https://www.consumer.ftc.gov/blog/2018/10/will-background-check-errors-deny-you-home; $3 million 

FCRA settlement puts tenant background screening at the forefront (Oct. 2018), 

https://www.ftc.gov/news-events/blogs/business-blog/2018/10/3-million-fcra-settlement-puts-tenantbackground-screening. 

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consumers of the outcome of disputes.23 The settlement included $72,000 in civil 

penalties. In Tricolor Auto Acceptance, LLC, the Commission alleged that the loan 

servicing department of an auto dealer failed to have written policies and procedures 

designed to ensure that the credit information it reported to CRAs was accurate and 

failed to properly investigate consumer disputes regarding the accuracy of credit 

information.24 The settlement included $82,000 in civil penalties. 

As to the CRAs themselves, the FTC has settled cases against background screening 

CRAs that compile background reports on consumers that may include driving records, 

employment and education history, eviction records, criminal records, and credit history 

for use in making employment and housing decisions. These settlements include 

allegations relating to inaccuracies in consumer reports. For example, in RealPage, Inc., 

the Commission alleged that a tenant background screening CRA failed to have 

reasonable procedures to ensure the maximum possible accuracy of consumer report 

information and associated some potential renters with criminal records that did not 

belong to them.25 The settlement included $3 million in civil penalties. In InfoTrack 

Information Services, Inc., the Commission alleged that an employment background 

screening CRA failed to have reasonable procedures to ensure the maximum possible 

accuracy of consumer report information and, as a result, provided inaccurate 

information suggesting that job applicants potentially were registered sex offenders.26 

The settlement included $1 million in civil penalties, which was suspended upon 

payment of $60,000 based on inability to pay. 

The FTC has also brought cases against check authorization CRAs for failing to comply 

with their accuracy obligations. Check authorization companies compile consumers’ 

personal information and use it to help retail merchants throughout the United States 

determine whether to accept consumers’ checks. In its settlements with Telecheck27 

and Certegy,

28 two of the nation’s largest check authorization companies, the 

Commission charged these companies with failing to follow FCRA accuracy procedures, 

failing to follow proper procedures for consumer disputes, and failing to establish and 

implement reasonable written policies regarding the accuracy of information the 

companies furnish to other CRAs. 

23 United States v. Credit Prot. Ass’n, LP, No. 3:16-cv-01255-D (N.D. Tex. filed May 9, 2016), 

https://www.ftc.gov/enforcement/cases-proceedings/142-3142/credit-protection-association. 24 United States v. Tricolor Auto Acceptance, LLC, No. 3:15-cv-3002 (N.D. Tex. filed Sept. 16, 2015), 

https://www.ftc.gov/enforcement/cases-proceedings/142-3073/tricolor-auto-acceptance-llc. 25 FTC v. RealPage, Inc, No. 3:18-cv-02737-N (N.D. Tex. filed Oct. 16, 2018), 

https://www.ftc.gov/enforcement/cases-proceedings/152-3059/realpage-inc. 26 United States v. Infotrack Info. Servs., Inc., No. 1:14-cv-02054 (N.D. Ill. filed Apr. 9, 2014), 

https://www.ftc.gov/enforcement/cases-proceedings/122-3092/infotrack-information-services-inc-et-al. 27 United States v. TeleCheck Servs., Inc., No. 1:14-cv-00062 (D.D.C. filed Jan. 16, 2014), 

https://www.ftc.gov/enforcement/cases-proceedings/112-3183/telecheck-services-inc. 28 United States v. Certegy Servs., Inc., No. 1:13-cv-01247 (D.D.C. filed Aug. 15, 2013), 

https://www.ftc.gov/enforcement/cases-proceedings/112-3183/telecheck-services-inc. 

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The FTC obtained $3.5 million in civil 

penalties against each company. 

A full list of the Commission’s law 

enforcement actions regarding 

consumer report accuracy in the last 

decade appears in Appendix B. 

III. CONCLUSION 

In the last decade, the Commission has 

brought more than 30 actions to enforce the 

FCRA against consumer reporting agencies 

(“CRAs”), users of consumer reports, and 

furnishers of information to CRAs. 

The FTC continues to look for education and enforcement opportunities around the 

issue of consumer report accuracy and disputes. Indeed, last December, the 

Commission hosted a public workshop, jointly with the CFPB, regarding issues affecting 

the accuracy of both traditional credit reports and employment and tenant background 

screening reports.29 The December workshop brought together stakeholders—including 

industry representatives, consumer advocates, and regulators—for a wide-ranging 

public discussion on the many issues that affect the accuracy of consumer reports. The 

Commission’s goal in co-hosting this workshop was to further educate itself on recent 

trends in consumer reporting accuracy,30 including (1) current practices of furnishers of 

information and compliance with accuracy requirements; (2) current accuracy topics for 

traditional credit reporting agencies; (3) accuracy considerations for background 

screening; and (4) navigating the dispute process. The agencies solicited public 

comments before and after the workshop, and the workshop record will assist the 

Commission in targeting its education and enforcement efforts in this area in the future. 

Thank you for the opportunity to provide the Commission’s report on credit report 

accuracy and consumer disputes. We look forward to continuing to work with Congress 

and this Committee on these important issues. 

29 See Accuracy in Consumer Reporting, An FTC/CFPB Workshop (Dec. 2019), 

https://www.ftc.gov/news-events/events-calendar/accuracy-consumer-reporting-workshop. 30 In 2012, the FTC published a congressionally mandated study that examined the accuracy of credit 

reports from the three nationwide consumer reporting agencies. Section 319 of the Fair and Accurate 

Credit Transactions Act of 2003: Fifth Interim Federal Trade Commission Report to Congress Concerning 

the Accuracy of Information in Credit Reports (Dec. 2012), https://www.ftc.gov/reports/section-319-fairaccurate-credit-transactions-act-2003-fifth-interim-federal-trade. 

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Appendix A: Selected FTC Consumer Education Resources on 

Disputing and Correcting Information in Consumer Reports 

1. Understanding Your Credit (Jan. 2020), 

https://www.consumer.ftc.gov/articles/understanding-your-credit. 

2. Credit repair: Fixing Mistakes on Your Credit Report (Jan. 2020), 

https://www.consumer.ftc.gov/blog/2020/01/credit-repair-fixing-mistakes-yourcredit-report. 

3. Fixing Your Credit (Mar. 2018), https://www.consumer.ftc.gov/articles/fixing-yourcredit. 

4. Background Checks (Mar. 2018), https://www.consumer.ftc.gov/articles/0157-

background-checks. 

5. Credit and Your Consumer Rights (Jun. 2017), 

https://www.consumer.ftc.gov/articles/0070-credit-and-your-consumer-rights. 

6. Disputing Errors on Credit Reports (Feb. 2017), 

https://www.consumer.ftc.gov/articles/0151-disputing-errors-credit-reports. 

7. Renting an apartment? Be prepared for a background check (Nov. 2016), 

https://www.consumer.ftc.gov/blog/2016/11/renting-apartment-be-preparedbackground-check. 

8. Sample Letter for Disputing Errors on Your Credit Report with Information 

Providers (Feb. 2014), https://www.consumer.ftc.gov/articles/0485-sample-letterdisputing-errors-your-credit-report-information-providers. 

9. Sample Letter for Disputing Errors on Your Credit Report (Aug. 2013), 

https://www.consumer.ftc.gov/articles/0384-sample-letter-disputing-errors-yourcredit-report. 

10.Free Credit Reports (Mar. 2013), https://www.consumer.ftc.gov/articles/0155-freecredit-reports. 

11.Credit Repair: How to Help Yourself (Nov. 2012), 

https://www.consumer.ftc.gov/articles/0058-credit-repair-how-help-yourself. 

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Appendix B: FTC Actions Since 2010 Alleging Violations of the 

FCRA’s Dispute and/or Accuracy Provisions 

1. FTC v. Real Page, Inc., No. 3:18-cv-02737-N (N.D. Tex. filed Oct. 16, 2018), 

https://www.ftc.gov/enforcement/cases-proceedings/152-3059/realpage-inc. 

2. United States v. Credit Prot. Ass’n, LP, No. 3:16-cv-01255-D (N.D. Tex. filed May 

9, 2016), https://www.ftc.gov/enforcement/cases-proceedings/142-3142/creditprotection-association. 

3. United States v. Tricolor Auto Acceptance, LLC, No. 3:15-cv-3002 (N.D. Tex. 

filed Sept. 16, 2015), https://www.ftc.gov/enforcement/cases-proceedings/142-

3073/tricolor-auto-acceptance-llc. 

4. United States v. TeleCheck Servs., Inc., No. 1:14-cv-00062 (D.D.C. filed Jan. 16, 

2014), https://www.ftc.gov/enforcement/cases-proceedings/112-3183/telecheckservices-inc. 

5. United States v. Infotrack Info. Servs., Inc., No. 1:14-cv-02054 (N.D. Ill. filed Apr. 

9, 2014), https://www.ftc.gov/enforcement/cases-proceedings/122-

3092/infotrack-information-services-inc-et-al. 

6. United States v. Instant Checkmate, Inc., No. 3:14-cv-00675-H-JMA (S.D. Cal. 

filed Apr. 9, 2014), https://www.ftc.gov/enforcement/cases-proceedings/122-

3221/instant-checkmate-inc. 

7. United States v. Consumer Portfolio Servs., Inc., No. 8:14-cv-00819-ABC-RNB 

(C.D. Cal. filed May 28, 2014), https://www.ftc.gov/enforcement/casesproceedings/112-3010/consumer-portfolio-services-inc. 

8. United States v. Certegy Servs., Inc., No. 1:13-cv-01247 (D.D.C. filed Aug. 15, 

2013), https://www.ftc.gov/enforcement/cases-proceedings/112-3183/telecheckservices-inc. 

9. In the Matter of Filquarian Publ’g, LLC; Choice Level, LLC and Joshua Linsk, 

FTC Matter No. 112 3195 (May 1, 2013), https://www.ftc.gov/enforcement/casesproceedings/112-3195/filiquarian-publishing-llc-choice-level-llc-joshua-linsk. 

10.United States v. Spokeo, Inc., No. 2:12-cv-05001-MMM-SH (C.D. Cal. filed June 

7, 2012), https://www.ftc.gov/enforcement/cases-proceedings/1023163/spokeoinc. 

11.United States v. HireRight Sols., Inc., No. 1:12-cv-01313 (D.D.C. filed Aug. 8, 

2012), https://www.ftc.gov/enforcement/cases-proceedings/102-313/hirerightsolutions-inc. 

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12.United States v. Asset Acceptance, LLC, No. 8:12-cv-00182-JDW-EAJ (M.D. Fla. 

filed Jan. 30, 2012), https://www.ftc.gov/enforcement/cases-proceedings/052-

3133/asset-acceptance-llc. 

13.United States v. Credit Bureau Collection Servs., Larry Ebert, and Brian Striker, 

No. 2:10-cv-00169-ALM –NMK (S.D. Ohio filed February 24, 2010), 

https://www.ftc.gov/enforcement/cases-proceedings/062-3226/credit-bureaucollection-services. 

14.United States v. First Advantage SafeRent, Inc., No. 8:10-cv-00090-PJM (D. Md. 

filed Jan. 14, 2010), https://www.ftc.gov/enforcement/cases-proceedings/082-

3016/first-advantage-saferent-inc-et-al-usa-ftc. 

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