|Received:||5/22/2006 4:06:08 PM|
|Subject:||Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies|
|Title:||Advance Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Parts 660 and 661|
Comments:A9: (policies, processes and procedures that furnishers should use to conduct reinvestigations) Furnishers should ALWAYS be required to reinvestigate disputed information all the way to the source documents upon which the information they’re reporting is based. This is just as important for debt collectors as for creditors, if not more so considering the advantages debt collectors find in reporting false information while refusing to acknowledge and properly reinvestigate disputes. Reinvestigation must require more than simply glancing at a computer screen or file and confirming that the CRA is reporting what the furnisher intended to report. Reinvestigation must involve collecting and reviewing the documents that PROVE their claim is accurate and being reported accurately. Furthermore debt collectors should be required to forward, at no charge, all of the relevant documentation to the consumer as standard procedure in resolving the dispute, rather than simply responding to the CRA that the account is “verified” while continuing to report inaccurate or intentionally misleading information with no proof whatsoever. --------------------- --------------------- A10: (policies and procedures of consumer reporting agencies for ensuring the accuracy and integrity of information received from furnishers) Some CRAs (most notably Experian) have been refusing to delete inaccurate address and other personal information, contending that this is “historical information” reported by their subscribers and is not disputable even if it’s inaccurate. Consequently, if a subscriber reports an incorrect address, name, SSN, or other info, the CRA may refuse to remove it because of their policy. How does this comply with the FCRA? Refusing to reinvestigate and delete information by classifying it as “historical” allows inaccurate and false information to remain on credit reports indefinitely, leading to confusion with other creditors and viewers of the credit report, and possibly encouraging or assisting in identity theft. --------------------- --------------------- Only complete, accurate and verifiable information should be on credit reports and in consumer credit files, regardless of how a CRA chooses to "classify" any item of information.