information on reports, with consumers fre-
quently expressing their frustrations about the 
burdensome and time-consuming process to dis-
puting items. 
(N) Other common types of credit report-
ing complaints submitted to the Consumer Bu-
reau related to the improper use of a report, 
trouble obtaining a report or credit score, 
CRAs’ investigations, and credit monitoring or 
identity protection. 
(O) In the summer 2015 ‘‘Supervisory 
Highlights’’, the Consumer Bureau noted that 
one or more of the largest CRAs failed to ade-
quately oversee furnishers to ensure that they 
were adhering to the CRA’s vetting policies and 
to establish proper procedures to verify public 
record information. 
(P) According to the fall 2016 ‘‘Super-
visory Highlights’’, Consumer Bureau exam-
iners determined that one or more debt collec-
tors never investigated indirect disputes that 
lacked detail or were not accompanied by at-
tachments with relevant information from the 
consumer. Examiners also found that notifica-
tions sent to consumers about disputes consid-
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ered frivolous failed to identify for the con-
sumers the type of material that they could pro-
vide in order for the debt collector to complete 
the investigation of the disputed item. 
(Q) A February 2014 Consumer Bureau 
report titled ‘‘Credit Reporting Complaint 
Snapshot’’ found that consumers are confused 
about the extent to which the nationwide CRAs 
are required to provide them with validation 
and documentation of a debt that appears on 
their credit report. 
(R) As evidence that the current system 
lacks sufficient market incentives for CRAs to 
develop more robust procedures to increase the 
accuracy and completeness of information on 
credit reports, litigation discovery documented 
by 
the 
National 
Consumer 
Law 
Center 
(‘‘NCLC’’), as part of a January 2009 report 
titled, ‘‘Automated Injustice: How a Mecha-
nized Dispute System Frustrates Consumers 
Seeking to Fix Errors in Their Credit Re-
ports’’, showed that at least two of the three 
largest CRAs use quota systems to force em-
ployees to process disputes hastily and without 
the opportunity for conducting meaningful in-
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vestigations. At least one nationwide CRA only 
allowed dispute resolution staff five minutes to 
handle a consumer’s call. Furthermore, these 
CRAs were found to have awarded bonuses for 
meeting quotas and punished those who didn’t 
meet production numbers with probation. 
(S) Unlike most other business relation-
ships, where consumers can register their satis-
faction or unhappiness with a particular credit 
product or service simply by taking their busi-
ness elsewhere, consumers have no say in 
whether their information is included in the 
CRAs databases and limited legal remedies to 
hold the CRAs accountable for inaccuracies or 
poor service. 
(T) Accordingly, despite the existing statu-
tory mandate for CRAs to follow reasonable 
procedures to assure the maximum possible ac-
curacy of the information whenever they pre-
pare consumer reports, numerous studies, the 
high volume of consumer complaints submitted 
to the Consumer Bureau about incorrect infor-
mation on consumer reports, and supervisory 
activities by the Consumer Bureau demonstrate 
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that CRAs continue to skirt their obligations 
under the law. 
(2) INCORRECT
INFORMATION
ON
CONSUMER 
REPORTS.— 
(A) Consumers are entitled to dispute er-
rors on their consumer reports with either the 
CRA, who issued the report, or directly with 
furnishers, who supplied the account informa-
tion to the CRA, and request that mistakes be 
deleted or removed. Consumers, who believe an 
investigation has not correctly resolved their 
dispute, however, have few options, other than 
requesting that a statement about the dispute 
be included with their future reports. 
(B) CRAs have a statutory obligation 
under the FCRA to perform a reasonable inves-
tigation by conducting a substantive and 
searching inquiry when a consumer disputes an 
item on their report. In doing so, CRAs must 
conduct an independent review about the accu-
racy of any disputed item and cannot merely 
rely 
on 
a 
furnisher’s 
‘‘rubber-stamp’’ 
verification of the integrity of the information 
they have provided to CRAs. 
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(C) 
The 
Federal 
Trade 
Commission 
(‘‘FTC’’), in a ‘‘Report to Congress Under Sec-
tion 319 of the Fair and Accurate Credit 
Transactions Act of 2003’’ released in Decem-
ber 2012, found that 26 percent of survey par-
ticipants identified at least one potentially ma-
terial error on their consumer reports, and 13 
percent experienced a change in their credit 
score once the error was fixed. 
(D) Consumer Bureau examiners have 
identified repeated deficiencies with the nation-
wide CRAs’ information collection. In the sum-
mer 2015 ‘‘Supervisory Highlights’’ released in 
June 2015, the Consumer Bureau noted contin-
ued weaknesses with CRAs’ methods and proc-
esses for assuring maximum possible accuracy 
in their reports. Examiners also found, with 
certain exceptions, no quality control policies 
and procedures in place to test consumer re-
ports for accuracy. 
(E) In its ‘‘Credit Reporting Complaint 
Snapshot’’ released in February 2014, the Con-
sumer Bureau found that consumers were un-
certain about the depth and validity of the in-
vestigations performed about a disputed item. 
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