Articles

Thirty, forty-five, and fifteen

The three periods in the dispute statute, what starts each one, and what you are owed at the end of each. Get these three numbers right and most of the confusion about disputes goes away.

Thirty, forty-five, and fifteen

The dispute statute has three numbers in it, and the confusion about disputes is almost always confusion about which one is running.

1. Thirty days, from receipt

Section 1681i(a)(1)(A): once a bureau receives notice of a dispute, it has thirty days to conduct a reasonable reinvestigation and record the current status of the item or delete it. Not thirty days from mailing. From receipt, which is the date on the green card. Which means: the day you write on the calendar is the day the card says, and everything else counts from there.

2. Forty-five days, if you add something

Section 1681i(a)(1)(B): if the consumer sends additional information relevant to the dispute during the thirty days, the bureau may extend the period by fifteen days, to forty-five. Which means: a "follow-up" letter with a new paragraph, or a second exhibit mailed on day ten, legally lengthens the wait. Send everything with the first letter, or wait for the results.

3. Fifteen days, from your request

Section 1681i(a)(7): after the reinvestigation, the consumer may request a description of the procedure used to determine accuracy, including the name, address and telephone number of any furnisher contacted, and the bureau must provide it within fifteen days of the request. Which means: this period starts when you ask, and you can only usefully ask after the results have arrived. Requesting it in the first letter is fine; the clock still starts when the results come.

The one that is not a number: five business days

Section 1681i(a)(6): the bureau must send written notice of the results within five business days after completing the reinvestigation. Which means: results can arrive as early as week two and as late as day thirty-five; a results letter on day twelve does not mean the bureau skipped anything.

Putting them on one line

Mail day 0. Green card back day 3 to 7. That date is the bureau's day zero. Results due thirty days later, forty-five if you sent more. Results letter in hand: if "verified," request the description of procedure (or note it was already requested); fifteen days for that. Then the next decision, with the description in hand.

Two pencils on the church table, one for each clock, because I used to confuse them too.

What the numbers are not

They are not the seven-year reporting period, which is a different section. They are not the thirty days a collector gives you to request validation, which is a different statute. And they are not a deadline for you: you may dispute an item at any time, as often as the facts warrant, and the only cost of a bad-faith second dispute is that § 1681i(a)(3) lets the bureau call it frivolous.

What to do instead of guessing

Write the three numbers on the front of the folder: thirty from receipt, forty-five if you add, fifteen from your request. How a dispute actually works has the rest of the process in order.

QualifyReady's plan puts all three on your calendar from the day the package is delivered. You send the letters on the days that count. Step one, today: find the green card from your last letter and write its date on the calendar, then count thirty. Know your file before your lender does.

If a file is standing between you and an approval

Upload your reports. In 72 hours you have the analysis, the plan and every letter drafted for your review. You send them. One price, paid once, from $199. No subscription.