This Month’s Challenge is sponsored by:



 
 
 
 

Correct!

(B) While 15 U.S.C. sec. 1681(i) only requires that a reinvestigation is required as to “information contained in the consumer’s file at a consumer reporting agency”, it is best practices to have a system in place as a reasonable procedure to note information that is disputed even when no file is still maintained. This allows the CRA to avoid reporting information that it has become aware is incorrect in the event a new report is requested on the consumer. No copy of any corrected or revised report should be sent to the end user at this point, as its permissible purpose is no longer valid. Of course, if the consumer requests that a report be sent to a certain end user, it would be appropriate to do so upon written request from that consumer.


Question: John Smith contacts you to dispute information you sent to an end user. The date of your submission of that information to your client was over a year ago. When you review your file you discover you no longer have any information on Mr. Smith. You verify, however, that the information Mr. Smith claims you reported is not accurate information that should be reported on him. What should you do?

A. You should advise Mr. Smith that you do not maintain any information on him so there is nothing further you can do.

B. You should advise Mr. Smith that you do not currently have any information on him, but that you will retain information regarding his dispute in your system so that if a report is requested on him in the future you can ensure that this incorrect information is not reported.

C. You should ask Mr. Smith to provide you with the list of end users that you provided his report to, and you should send them a revised report omitting the disputed information.

D. (B) and (C).



 

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