FCRA Compliance Guide for Data Furnishers

1. Duty of Accuracy (Section 623)

• Provide accurate information to credit bureaus
• Update information when you learn it is incomplete or inaccurate
• Do not report information you know or have reasonable cause to believe is inaccurate
• Maintain reasonable written policies and procedures for data accuracy

2. Dispute Investigation Requirements

When a consumer disputes information through a credit bureau:

• 30-day timeline: Investigate and respond within 30 days (45 days if the consumer provides additional relevant information)
• Reasonable investigation: Conduct a thorough review of all relevant information
• Report results: Provide results of the investigation to the credit bureau
• Correct or delete: If information is inaccurate, incomplete, or unverifiable, you must correct or delete it
• Notify all bureaus: If you reported to multiple bureaus, notify all of them of any corrections

3. Direct Dispute Handling

When a consumer disputes information directly with you (not through a bureau):

• Accept disputes orally, in writing, or electronically
• Conduct a reasonable investigation within 30 days
• Update credit bureaus if the investigation reveals inaccuracies
• Do not report information solely because the consumer disputes it, if you reasonably believe it to be accurate

4. Negative Information Notification

Before reporting negative information for the first time:

• Provide clear notice to the consumer about their rights
• Notice must be provided before or within 30 days after reporting
• Notice can be included on account statements, as a separate mailing, or electronically
• Must include your contact information and the consumer's dispute rights

5. Special Situations

Deceased Consumers

• Report the account appropriately to reflect the consumer's deceased status
• Update all bureaus you reported to

Identity Theft

• Block fraudulent information within 4 business days of receiving a valid identity theft report
• Notify credit bureaus that information results from identity theft
• Do not sell or transfer debt known to result from identity theft

Military Service Members

• Report accounts under Servicemembers Civil Relief Act (SCRA) protection appropriately
• Do not report as delinquent if a payment was reduced due to military service

Medical Debt

• Medical debts under $500 cannot be reported (as of 2025)
• 180-day waiting period required before reporting medical collections
• Paid medical collections must be deleted from the credit report