(d) is the correct
answer. Section 611 (15 USC 1681i(f)(3)(B)) requires telephonic
notification (which means you, as a reseller, should document
your efforts to comply with this requirement). This appears
to be the only place in the FCRA where a specific type of
communication is required. If you do not have the telephone
number for the consumer, you should contact your end user
and try to obtain this information. This is a potential
hidden trap for CRAs related to their reseller activities.
The following is the specific language from the Statute.
Inc. runs a credit report on an applicant for XYZ Company.
The applicant files a dispute directly with TransUnion,
who then sends the results to CRA. CRA did not even know
there was a reinvestigation going on and has no reinvestigation
file. What should CRA do with the results sent to it by
Notify XYZ of the results, explaining that the applicant
disputed the issue directly with TransUnion.
Call the applicant immediately to advise of the results.
Notify the applicant of the results, sending a cover letter
explaining what was done, sending a copy of the report,
and the FCRA Summary of Rights.
All of the above.
(a) and (c)