FCRA — the agency's duties as a furnisher when reporting to the bureaus

Authority

Fair Credit Reporting Act, 15 U.S.C. § 1681s-2 (furnisher duties) and § 1681c (obsolescence — what may appear on a report and for how long), plus CFPB Regulation V furnisher rules, 12 CFR §§ 1022.40–43 (Subpart E — Duties of Furnishers). Enforced by the CFPB/FTC and state officials; § 1681s-2(b) duties (post-ACDV) also carry private liability, while § 1681s-2(a) duties are agency-enforced only (§ 1681s-2(c)–(d)).

⚠️ Metro 2 is NOT covered here — and has no free official source. The field-level Metro 2® reporting format (Base Segment, K2 segment for debt buyers/collection agencies, compliance condition codes like XB, status codes, DOFD field 25, etc.) is defined by the Consumer Data Industry Association's Credit Reporting Resource Guide (CRRG) — a paid, copyrighted CDIA publication with no official government mirror. This page covers the legal duties only. Any Metro 2 implementation requires a licensed CRRG; do not take field semantics from blogs or memory.

Operative text

Accuracy — the two prohibition tiers

(A) Reporting information with actual knowledge of errors A person shall not furnish any information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information is inaccurate. — 15 U.S.C. § 1681s-2(a)(1)(A)

(B) Reporting information after notice and confirmation of errors A person shall not furnish information relating to a consumer to any consumer reporting agency if— (i) the person has been notified by the consumer, at the address specified by the person for such notices, that specific information is inaccurate; and (ii) the information is, in fact, inaccurate. — 15 U.S.C. § 1681s-2(a)(1)(B)

Duty to correct and update

(2) Duty to correct and update information A person who— (A) regularly and in the ordinary course of business furnishes information to one or more consumer reporting agencies about the person's transactions or experiences with any consumer; and (B) has furnished to a consumer reporting agency information that the person determines is not complete or accurate, shall promptly notify the consumer reporting agency of that determination and provide to the agency any corrections to that information, or any additional information, that is necessary to make the information provided by the person to the agency complete and accurate, and shall not thereafter furnish to the agency any of the information that remains not complete or accurate. — 15 U.S.C. § 1681s-2(a)(2)

Duty to flag disputed information

(3) Duty to provide notice of dispute If the completeness or accuracy of any information furnished by any person to any consumer reporting agency is disputed to such person by a consumer, the person may not furnish the information to any consumer reporting agency without notice that such information is disputed by the consumer. — 15 U.S.C. § 1681s-2(a)(3)

Date of first delinquency (DOFD) — the anchor of the 7-year clock

(5) Duty to provide notice of delinquency of accounts (A) In general A person who furnishes information to a consumer reporting agency regarding a delinquent account being placed for collection, charged to profit or loss, or subjected to any similar action shall, not later than 90 days after furnishing the information, notify the agency of the date of delinquency on the account, which shall be the month and year of the commencement of the delinquency on the account that immediately preceded the action. — 15 U.S.C. § 1681s-2(a)(5)(A)

For a collector/debt buyer that cannot directly establish DOFD, § 1681s-2(a)(5)(B) prescribes the hierarchy (quoted from the statute):

(i) the person reports the same date of delinquency as that provided by the creditor to which the account was owed at the time at which the commencement of the delinquency occurred, if the creditor previously reported that date of delinquency to a consumer reporting agency; (ii) the creditor did not previously report the date of delinquency to a consumer reporting agency, and the person establishes and follows reasonable procedures to obtain the date of delinquency from the creditor or another reliable source and reports that date to a consumer reporting agency as the date of delinquency; or (iii) the creditor did not previously report the date of delinquency to a consumer reporting agency and the date of delinquency cannot be reasonably obtained as provided in clause (ii), the person establishes and follows reasonable procedures to ensure the date reported as the date of delinquency precedes the date on which the account is placed for collection, charged to profit or loss, or subjected to any similar action, and reports such date to the credit reporting agency. — 15 U.S.C. § 1681s-2(a)(5)(B)(i)–(iii)

ACDV disputes routed through a bureau — § 1681s-2(b)

(b) Duties of furnishers of information upon notice of dispute (1) In general After receiving notice pursuant to section 1681i(a)(2) of this title of a dispute with regard to the completeness or accuracy of any information provided by a person to a consumer reporting agency, the person shall— (A) conduct an investigation with respect to the disputed information; (B) review all relevant information provided by the consumer reporting agency pursuant to section 1681i(a)(2) of this title; (C) report the results of the investigation to the consumer reporting agency; (D) if the investigation finds that the information is incomplete or inaccurate, report those results to all other consumer reporting agencies to which the person furnished the information and that compile and maintain files on consumers on a nationwide basis; and (E) if an item of information disputed by a consumer is found to be inaccurate or incomplete or cannot be verified after any reinvestigation under paragraph (1), for purposes of reporting to a consumer reporting agency only, as appropriate, based on the results of the reinvestigation promptly— (i) modify that item of information; (ii) delete that item of information; or (iii) permanently block the reporting of that item of information. (2) Deadline A person shall complete all investigations, reviews, and reports required under paragraph (1) regarding information provided by the person to a consumer reporting agency, before the expiration of the period under section 1681i(a)(1) of this title within which the consumer reporting agency is required to complete actions required by that section regarding that information. — 15 U.S.C. § 1681s-2(b)(1)–(2)

The referenced § 1681i(a)(1) period (which caps both ACDV and direct-dispute handling):

(A) In general Subject to subsection (f) and except as provided in subsection (g), if the completeness or accuracy of any item of information contained in a consumer's file at a consumer reporting agency is disputed by the consumer and the consumer notifies the agency directly, or indirectly through a reseller, of such dispute, the agency shall, free of charge, conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate and record the current status of the disputed information, or delete the item from the file in accordance with paragraph (5), before the end of the 30-day period beginning on the date on which the agency receives the notice of the dispute from the consumer or reseller. (B) Extension of period to reinvestigate Except as provided in subparagraph (C), the 30-day period described in subparagraph (A) may be extended for not more than 15 additional days if the consumer reporting agency receives information from the consumer during that 30-day period that is relevant to the reinvestigation. — 15 U.S.C. § 1681i(a)(1)(A)–(B)

Reg V — reasonable written policies and procedures

(a) Policies and procedures. Each furnisher must establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information relating to consumers that it furnishes to a consumer reporting agency. The policies and procedures must be appropriate to the nature, size, complexity, and scope of each furnisher's activities. (b) Guidelines. Each furnisher must consider the guidelines in appendix E of this part in developing its policies and procedures required by this section, and incorporate those guidelines that are appropriate. (c) Reviewing and updating policies and procedures. Each furnisher must review its policies and procedures required by this section periodically and update them as necessary to ensure their continued effectiveness. — 12 CFR § 1022.42(a)–(c)

Reg V — direct disputes (consumer disputes straight to the agency, no bureau in the middle)

(a) General rule. Except as otherwise provided in this section, a furnisher must conduct a reasonable investigation of a direct dispute if it relates to: (1) The consumer's liability for a credit account or other debt with the furnisher, such as direct disputes relating to whether there is or has been identity theft or fraud against the consumer, whether there is individual or joint liability on an account, or whether the consumer is an authorized user of a credit account; (2) The terms of a credit account or other debt with the furnisher, such as direct disputes relating to the type of account, principal balance, scheduled payment amount on an account, or the amount of the credit limit on an open-end account; (3) The consumer's performance or other conduct concerning an account or other relationship with the furnisher, such as direct disputes relating to the current payment status, high balance, date a payment was made, the amount of a payment made, or the date an account was opened or closed; or (4) Any other information contained in a consumer report regarding an account or other relationship with the furnisher that bears on the consumer's creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. — 12 CFR § 1022.43(a)

Handling duties and the deadline:

(e) Duty of furnisher after receiving a direct dispute notice. After receiving a dispute notice from a consumer pursuant to paragraphs (c) and (d) of this section, the furnisher must: (1) Conduct a reasonable investigation with respect to the disputed information; (2) Review all relevant information provided by the consumer with the dispute notice; (3) Complete its investigation of the dispute and report the results of the investigation to the consumer before the expiration of the period under section 611(a)(1) of the FCRA (15 U.S.C. 1681i(a)(1)) within which a consumer reporting agency would be required to complete its action if the consumer had elected to dispute the information under that section; and (4) If the investigation finds that the information reported was inaccurate, promptly notify each consumer reporting agency to which the furnisher provided inaccurate information of that determination and provide to the consumer reporting agency any correction to that information that is necessary to make the information provided by the furnisher accurate. — 12 CFR § 1022.43(e)

Where a direct dispute must be sent to trigger the duty (§ 1022.43(c)): the furnisher's address shown on the consumer report, an address the furnisher clearly and conspicuously designated, or — if none was designated — any business address of the furnisher (§ 1022.43(c)(3)). Required dispute contents are at § 1022.43(d) (account identification, the specific information disputed + basis, supporting documentation).

Frivolous/irrelevant out — with its own notice deadline:

(2) Notice of determination. Upon making a determination that a dispute is frivolous or irrelevant, the furnisher must notify the consumer of the determination not later than five business days after making the determination, by mail or, if authorized by the consumer for that purpose, by any other means available to the furnisher. — 12 CFR § 1022.43(f)(2)

Exceptions (§ 1022.43(b)): no direct-dispute duty for disputes about identifying information, employers, inquiries, public-record information, fraud/active-duty alerts, information furnished by another furnisher, or disputes reasonably believed to come from/through a credit repair organization.

Obsolescence — the 7-year rule and its exact start date

(a) Information excluded from consumer reports Except as authorized under subsection (b), no consumer reporting agency may make any consumer report containing any of the following items of information: … (4) Accounts placed for collection or charged to profit and loss which antedate the report by more than seven years. — 15 U.S.C. § 1681c(a)(4)

(c) Running of reporting period (1) In general The 7-year period referred to in paragraphs (4) and (6) of subsection (a) shall begin, with respect to any delinquent account that is placed for collection (internally or by referral to a third party, whichever is earlier), charged to profit and loss, or subjected to any similar action, upon the expiration of the 180-day period beginning on the date of the commencement of the delinquency which immediately preceded the collection activity, charge to profit and loss, or similar action. — 15 U.S.C. § 1681c(c)(1)

Plain English

Interpretation — the quotes above win on any conflict.

• Never furnish what you know (or have real reason to believe) is wrong; once you determine something you furnished is wrong, you must promptly correct it everywhere and stop re-furnishing the bad data.
• Every disputed tradeline must carry the dispute flag (in Metro 2 practice this is a compliance condition code — field semantics per the licensed CRRG only).
• DOFD is sacred. Report it within 90 days of first furnishing a collection account; it is the month/year the consumer first went delinquent and never got current again before placement/charge-off. The bureau's 7-year purge clock = that DOFD + 180 days, then 7 years. Re-aging (moving DOFD forward on placement, sale, or payment) is the classic furnisher violation.
• Two dispute pipelines, same deadline: ACDVs via the bureau (§ 1681s-2(b)) and direct disputes to the agency (§ 1022.43) both must be investigated and answered within the § 1681i(a)(1) window quoted above (30 days from the consumer's dispute, extendable by up to 15 days when the consumer supplies relevant information mid-investigation). Direct disputes additionally require reporting results to the consumer.
• A written furnishing policy is itself a legal requirement (§ 1022.42 + Appendix E guidelines) — appropriate to the agency's size and reviewed periodically.
• Only § 1681s-2(b) (post-ACDV) failures are privately actionable; § 1681s-2(a) accuracy/DOFD duties are enforced by regulators — but CFPB consent orders against collectors lean on exactly these.

Traps / edge cases

• The 7-year clock never restarts — not on placement, not on sale to a debt buyer, not on partial payment. § 1681c(c)(1) pegs it solely to the original delinquency commencement + 180 days.
• Direct disputes sent to any business address count if the agency never designated a dispute address (§ 1022.43(c)(3)) — designate one and print it on validation notices, or every branch mailbox is a compliance intake.
• The frivolous/irrelevant determination has its own 5-business-day notice duty with required contents (§ 1022.43(f)(2)–(3)).
• The credit-repair-organization exception (§ 1022.43(b)(2)) requires a reasonable belief — blanket-ignoring templated disputes is how furnishers get sued under (b) when the same dispute later arrives via ACDV.
• § 1681s-2(a)(1)(B) liability requires the info be "in fact, inaccurate" — but (a)(1)(A)'s "reasonable cause to believe" tier doesn't wait for consumer notice.
• Interaction with Reg F: 12 CFR 1006.30(a) (see ./reg-f/credit-reporting-prereqs.md) bars furnishing before the consumer has been contacted about the debt (passive-collection ban) — a pure Reg F rule that sits on top of everything here.
• FCRA § 1681c is a duty on the CRA, not the furnisher — but furnishing a DOFD that makes obsolete debt look reportable is an accuracy problem under § 1681s-2(a).

Related

• ./reg-f/credit-reporting-prereqs.md — Reg F bar on furnishing before consumer contact
• ./reg-f/call-frequency.md
• ./fdcpa/communications.md