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Need help with a non-responsive 623 dispute

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Lyythine
Established Contributor

Need help with a non-responsive 623 dispute

I've been helping a good friend to clean-up his credit report over the past several months.  As part of that process, we filed a 623 dispute on two First Premier accounts which had very different and wrong reporting among the 3 credit bureaus. In any case, it is now past the 30 days they had to respond and he has heard and/or received nothing.  At this point, how do I go about helping him move forward to have these removed?  File a dispute with CRB, CFPB, BBB or all 3?   Thanks in advance for the help!

Message 1 of 9
8 REPLIES 8
RobertEG
Legendary Contributor

Re: Need help with a non-responsive 623 dispute

Rather than separately defining the response period for direct disputes, the FCRA and the implementing regs simply define it as the same period that a consumer reporting agency has to complete a dispute made thru them.

 

The furnisher thus has 30 days from date of the dispute to complete their investigation.  They have an additional five business days thereafter to mail their notice of results.

 

Thus, 30 days investigation time plus 5 days plus any intervening weekends or holidays plus normal mail time results in approx 40 days from date of dispute before one should begin to contest lack of timely completion.

 

If they fail to comply, then a formal complaint to the CFPB would be in order.

The CRA has no part in a direct dispute, and the BBB has no enforcement authority.

Message 2 of 9
cartwrna
Valued Contributor

Re: Need help with a non-responsive 623 dispute

How did you send your 623 dispute?
Don’t take your credit for granted, use it with care! These days, catch me in the bankruptcy forum!?
Message 3 of 9
Lyythine
Established Contributor

Re: Need help with a non-responsive 623 dispute

Thanks for the responses! I had him send them CMRR

Message 4 of 9
Lyythine
Established Contributor

Re: Need help with a non-responsive 623 dispute

I should also mention, since I failed to have it in my initial post that I had him dispute the accounts with all 3 CB before the 623.  I just wasn't sure how to proceed after the failed response from First Premier.  

Message 5 of 9
Anonymous
Not applicable

Re: Need help with a non-responsive 623 dispute

If you already disputed with he cra then the OC can mark your dispute as frivelous as they are only required to respond once unless you supplied new information. 

Message 6 of 9
RobertEG
Legendary Contributor

Re: Need help with a non-responsive 623 dispute

+1

See the implementing rules at 16 CFR 660.4(f).

Message 7 of 9
Lyythine
Established Contributor

Re: Need help with a non-responsive 623 dispute

Wait, I thought you had to dispute it with the CRA first before you filed a 623?  The CRA came back with verified and nothing was changed despite it being reporting wrong with multiple innacuracies.  

Message 8 of 9
gdale6
Moderator Emeritus

Re: Need help with a non-responsive 623 dispute


@Lyythine wrote:

Wait, I thought you had to dispute it with the CRA first before you filed a 623?  The CRA came back with verified and nothing was changed despite it being reporting wrong with multiple innacuracies.  


You do, that is correct. If they dont respond within 40 days, you have to allow for weekends/holidays and mailing time then file a CFPB complaint.

Message 9 of 9
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