They apparently attempt to create their own confusion over the term "dispute." There are an alarming number of recent posts stating that debt collectors are rather routinely treating DV requests as FCRA "disputes."
FDCPA 809(b) does use the term "dispute" as a basis for a DV request, but the "dispute" is over the debt itself, in whole or in part, and is just a statement by the consumer that requires no documentation.
Disputes under the FCRA are directed at the accuracy of information reported to a consumer credit file, and require some documentation of an asserted inaccuracy.
They are disputes of a totally different type and content.
Since the DV is sent directly to the debt collector, the ONLY way for them to "misinterpret" it as an FCRA dispute is to consider it as a direct dispute under FCRA 623(a)(8).
Since a DV does not contain an assertion of an inaccuracy in credit reporting, or any supporting documentation, if they had interpreted the DV as a dispute, they should have immediately held it to be "frivoulous or irrelevant" due to lack of any allegation or support for an assertion of inaccuracy. They dont do that.
If they had considered it to be a valid direct dispute, they are accepting obligation to conduct an investigation of some unasserted inaccuracy, and report the results back to you within 30 days. They dont do that either.
Rather, they report a pending dispute, and often ask the creditor for more info to support their "dispute". Not appropriate, as they should either dismiss it or act on it, not ask for more info.
It seems to have become the tactic d'jour of many debt collectors to tie the consumer in knots.
