FCRA Compliance Guide for Data Furnishers

1. Duty of Accuracy (Section 623)

You must:

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

Best Practice: Review all data before reporting and implement quality control procedures to catch errors.

2. Dispute Investigation Requirements

When a consumer disputes information:

• 30-day timeline: Investigate and respond within 30 days (45 days if consumer provides additional relevant info)
• Reasonable investigation: Conduct a thorough review of relevant information
• Report results: Provide results to 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 corrections

3. Direct Dispute Handling

When a consumer disputes directly with you:

• Provide a notice about their right to dispute
• Accept disputes orally, in writing, or electronically
• Investigate disputes received directly from consumers
• Update credit bureaus if investigation reveals inaccuracies
• Do not report information solely because consumer disputes it (if you reasonably believe it's accurate)

4. Negative Information Notification

Before reporting negative information for the first time:

• Provide clear notice to consumer about their rights
• Notice must be provided before or within 30 days after reporting
• Notice can be on account statements, separate mailings, or electronically
• Must include contact information and dispute rights

5. Special Situations

Deceased Consumers:

• Must report account as "Deceased - Do Not Issue Credit"
• Update all bureaus you reported to

Identity Theft:

• Block fraudulent information within 4 business days of receiving 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 SCRA protection appropriately
• Do not report as delinquent if payment was reduced due to military service

Medical Debt:

• As of 2025, medical debts under $500 cannot be reported
• 180-day waiting period before reporting medical collections
• Must delete paid medical collections