On January 7, the CFPB filed a complaint against a consumer reporting agency, alleging violations of the FCRA and the CFPA’s prohibition on unfair acts or practices. The complaint alleges the company failed meet its dispute-resolution obligations under the FCRA. In particular, the Bureau alleges three core issues: (i) faulty dispute intake procedures, in which the company failed to accurately convey all relevant information from consumers to data furnishers, often mischaracterizing or omitting critical details of disputes; (ii) an “over-reliance” on furnishers’ responses during reinvestigations, even when those responses were improbable or contained inconsistencies; and (iii) providing “confusing, ambiguous, incorrect, and internally inconsistent” reinvestigation result notices. In addition, the complaint identifies several other issues, including the company’s failure to reinvestigate disputes within the FCRA’s required timeline, its refusal to reinvestigate hard inquiry disputes, and its failure to ensure previously deleted tradelines are not improperly reinserted.

The CFPB seeks injunctive relief to prevent future violations, monetary redress for consumers harmed by these practices, disgorgement of any ill-gotten gains, and civil money penalties.