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The direct dispute is real. The remedy runs through the bureau.

A post says to skip the bureaus and dispute straight to the bank under Section 623, where the bank faces civil liability if it can't produce your signed contract. The door is real. The liability sits behind the other one. Both doors, in order.

The direct dispute is real. The remedy runs through the bureau.

Section 623 of the Fair Credit Reporting Act, codified at 15 U.S.C. § 1681s-2, puts two different duties on the company that reports your account. A post going around this week tells you to skip the bureaus and write straight to the bank, because that is where the civil liability is. It has the two duties backwards. Which means: if you follow it, you give up the only one of the two you can enforce yourself.

Here is the section, read.

The two duties

Subsection (a)(8) is the direct dispute. You write to the furnisher at the address it names for disputes, and Regulation V, § 1022.43, makes it investigate and answer within the same thirty days a bureau gets. That door is real, and I walked you through the letter in April.

Subsection (b) is the duty that starts when a bureau forwards your dispute, and it is longer: the furnisher has to investigate, review everything the bureau sent along with it, report the result back to that bureau, and correct what it got wrong at every bureau it reports to. Both are real.

Then subsection (c) says the two sections that give a consumer damages, §§ 1681n and 1681o, do not apply to subsection (a). Subsection (d) hands subsection (a) to federal and state agencies. Which means: a furnisher that fumbles your direct dispute answers to a regulator. A furnisher that fumbles a dispute the bureau forwarded answers to you.

The scanner

The post is right that a bureau sends your dispute to the furnisher through an automated system, as a code. It leaves out § 1681i(a)(2)(B), which requires the bureau to pass along all the relevant information you sent. Which means: the cure for a two-digit code is a document.

I spent eleven years in a bank's back office where the files had no faces. Disputes came across my desk as codes, and some came with a page attached: a statement, a payoff letter, a teller's receipt. The ones with a page got read longer. I was not fast. My supervisor once timed me at eleven minutes on one statement, and she was not complimenting me.

The contract

Nothing in § 1681s-2 or in Regulation V requires a furnisher to produce your signed agreement. The standard is a reasonable investigation of the information you disputed. Which means: "send me the original contract or delete it" asks for something the law does not require and disputes nothing in particular. The bank can answer it with a form letter, and usually does.

Both doors, in order

  1. Write to the bureau first. One account, one field, the value printed, the value that is true, and the document that proves it, enclosed. The six lines are the whole letter. This is the dispute that reaches subsection (b).
  2. Calendar thirty days from the date on the green card. That is the bureau's window under § 1681i(a)(1).
  3. Write to the furnisher directly when its own records are the proof. A payment it received and posted late. A payoff it confirmed in writing. A balance its own statement contradicts. Send it to the dispute address it names, and expect a correction or a letter, not a lawsuit.
  4. If both come back verified and your document still says otherwise, ask the bureau for its description of procedure under § 1681i(a)(7) and keep every page. That is the file a lawyer reads, if one ever needs to. I'm not a lawyer, and step four is where you stop reading me.

QualifyReady drafts both letters, in that order, and you send them. If the read tags an item leave alone and you want the letter anyway, ask. It is your report. You supply the specifics, the read says once why it disagrees, and the letter gets written.

Step one: if you mailed a contract demand this week, write the bureau letter for that account by Friday the 25th, with the document enclosed, and send it certified.

If a file is standing between you and an approval

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