FCRA §609(a)(1) compels a CRA to disclose to the consumer "all information in the consumer's file at the time of the request".
FCRA §623(a)(5) requires creditors to report DOFD to the CRA.
FCRA §603(g) defines a consumer file as "all of the information on that consumer recorded and retained by a consumer reporting agency regardless of how the information is stored."
It seems to me that if a consumer disclosure is subject to §609, then it's a violation if the CRA does not include the DOFD.
Anyone know whether all disclosures to consumers are subject to §609? Whether it's a FACTA request, a report purchased from the CRA or a reseller, an updated report after a dispute investigation is concluded, et al.?