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As I understand the post, you are asking whether violations of certain federal statutes or regulations unrelated to the validity of the debt are basis for requiring a creditor to delete otherwise accurate accounts reporting valid debts.
A dispute under the FCRA only relates to the accuracy of the information identified in the dispute. The requirment that the CRA delete inaccurate information only applies to the specific information that is subject of the dispute, and then only if the information is not either verified or corrected by the CRA.
Assertions of impermissible disclosure of your information to others does not relate to inaccuracy of their credit reporting per se, and does not carry a statutory requirment to delete accurate reporting. Those are matters you can pursue either by way of complaint to regulatory agencies or by separate civil action apart from the accuracy of their credit reporting.
The letter is addressed to the furnisher of the information, and not to a CRA.
It would thus be considered a direct dispute under FCRA 623(a)(8), and not a dispute being investigated by a CRA.
Notwithstanding your assertion that the contents of the letter do not comprise a frivolous dispute, the implementing rules for the direct dispute process permit a furnisher to dismiss any dispute as frivolous or irrelevant if it does not provide adequate support for a showing of inaccuracy in the reported information. See 16 CFR 660.4 et seq.
The assertion of a violation of other federal banking regs is not basis for showing inaccuracy of their credit reporting, and thus the "dispute" could be dismissed as frivolous or irrelevant without any need for investigation.
Wait for their response.
It is hard to say how they will treat it since it does not specifically assert to be a direct dispute under FCRA 623(a)(8).
If they treat it as a formal direct dispute, they will likely dismiss it as frivolous or irrelevant on the basis that it does not identify any specific inaccuracy in its reporting per se. However, they may verify their current reporting as accurate, and thus formally conclude the "dispute."
Or they may simply treat as an informal complaint, and not as a direct dispute, in which case they can say whatever they please or not respond at all.