|Received:||5/22/2006 9:51:23 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:Furnishers routinely do not investigate disputes from consumers. Standard practice in the banking industry is to circumvent the 30 day period prescribed for CRA reinvestigations wherein the furnisher must attest to the accuracy of their reported trade line by responding to a consumer's request for verification with an "Affidavit of Fraud." When the dispute lies in the dates or the amounts on the reported trade line, or in the lack of data in half the data fields, such a form is non responsive and appears designed to circumvent an investigation. When a consumer writes back that the fraud affidavit is non responsive and ask for substantiation of the debt, as reported, the data furnisher drops the ball. They update and verify the trade line stands as is with no change. The CRAs then refuse to reinvestigate. The data furnisher ignores all further correspondence from the consumer. The consumer is stuck with re-aged accounts, or inaccurate payment histories reflecting late payments or nonpayment where none exist. CRAs routinely do not accept any documentation from the consumer because it doesn't fit into their automated "verification" process that must be coded into like two digit codes. Please require and/or clarify that ALL data furnishers must be responsive to consumers requests for validation pursuant to the FDCPA and must do so within the 30 day time period prescribed by the FTC.