15 U.S.C. § 1681i
FCRA §611 reinvestigation software for agencies
TL;DR
FCRA §611 requires a consumer reporting agency to reinvestigate disputed information, generally within 30 days after it receives the dispute. Information found inaccurate, incomplete, or unverifiable must be deleted or modified. A missing optional record does not itself require deletion.
Definition
FCRA §611 reinvestigation software organizes a dispute, the facts supporting it, the mailing record, and the agency's response so a credit team can follow 15 U.S.C. § 1681i without treating every document request as a deletion rule.
What FCRA §611 (15 U.S.C. § 1681i) actually requires
A consumer may dispute the completeness or accuracy of information in the consumer's file. The consumer reporting agency must conduct a reasonable reinvestigation, generally within 30 days after receiving the dispute, subject to permitted extensions and the free-disclosure rules in the statute.
If the investigation finds the information inaccurate, incomplete, or unverifiable, the agency must promptly delete or modify it as appropriate under § 1681i(a)(5). Results notice generally follows within five business days after completion.
After reinvestigation, a consumer may request the description required by § 1681i(a)(7): the procedure used, the business name and address of any furnisher contacted, and a telephone number if reasonably available. That description is due within 15 days after the agency receives the request. Automation alone does not prove the investigation was unreasonable.
- The clock runs from receipt of the dispute, not from the day a letter was drafted.
- A provider's production status, or a mailing estimate, is not statutory receipt.
- Failure to send every requested document does not itself require deletion or establish liability.
- A direct furnisher dispute is a separate duty under 12 CFR § 1022.43, with exceptions that include some credit-repair-organization prepared forms.
How an agency uses this
1. State the specific inaccuracy
Identify the tradeline, the field in dispute, and the facts that make the reporting inaccurate, incomplete, or unverifiable. A blanket demand for every record is not an FCRA §611 dispute.
2. Send the dispute and preserve the receipt
Mail or submit the dispute, then record confirmed receipt separately from the send date. Vindex does not start a legal response window from a test letter or from provider completion alone.
3. Track the reinvestigation window
Count generally 30 days from confirmed receipt, and account for a permitted extension before treating the window as elapsed.
4. Request the procedure description if needed
After the reinvestigation, request the § 1681i(a)(7) description. The 15-day description period starts when the agency receives that request.
Direct answers
Does FCRA §611 require a credit bureau to delete an item it cannot document in full?
No. Section 611 requires deletion or modification when information is found inaccurate, incomplete, or cannot be verified. Failure to furnish every document a letter requests does not itself require deletion.
When does the FCRA §611 30-day period start?
The reinvestigation period generally starts when the consumer reporting agency receives the dispute. A mail date, a print date, or a vendor completion status is not the same event as receipt.
What is a method-of-verification request under FCRA §611?
It is the post-reinvestigation request for the procedure description in 15 U.S.C. § 1681i(a)(7), including the furnisher contacted. The agency generally has 15 days after receiving that request to provide the description.
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