While a decision to initially report to a CRA is voluntary, once a creditor has reported information, they thereafter bear the responsibility under FCRA 623(a)(2) to "promptly" update any information as necessary to maintain its current accuracy. Thus, the issue becomes whether there are any changes in reported information that require update.
The FCRA does not set a specific period, such as monthly, for update of reporting, as need for update is triggered by when they become aware of a change, and thus there is no set date upon which to base a determination of specific period.
Section 623(a)(2) chooses to use the broader term of "prompt" update, which is subjectiive.
A reasonable interpretation of "prompltly" would be in their next regular reporting cycle after they are clearly aware of the change.
If information has clearly changed and the creditor is shown to be aware of the change, such as depositing a payment, and no "prompt" update is filed, such as the passage of several normal monthly reporting cycles, then a consumer could support a dispute based on lack of compliance with FCRA 623(a)(2).
Lack of update since August could be reasonable if a change did not become known until late August, and was not forwarded to their reporting department prior to their regular September update. I would wait at least two months before asserting a presumed violation of the broad and subjective "promptness" standard of section 623(a)(2).
