If your DV was timely, which would be the case if they never sent dunning notice, then their "penalty" is that they must cease active collection on the debt until such time as they choose to provide the requested debt verification. Violation of the DV process occurs due to continued collection activities prior to debt validation.
As stated, the CRAs are not involved in debt collection practices issues under the FDCPA. Disputes to a CRA are directed at accuracy of their credit reporting under the FCRA, not validity of the debt.
Any dispute asserting failure to have validated under the FDCPA can be dismissed by the CRA without any reinvestigation on their part or referreal to the debt collector as lacking an asserted inaccuracy in credit reporting. Even if they chose to forward the dispute to the debt collector and conduct an reinvestigation, the debt collector is only required to respond that they have conducted their investigation, and find the information to be accurate. It does not requre them to provde any documentation or "prove" the validity of the debt. The same applies to verification in response to a DV request. You get statement that they have conducted a reasonable investigation, and their fnding is supported by the results of that investigation.
The CRA did more than what was required by treating your complaint as an actual dispute when there was no basis fot them to have done so.
You at least received a statement from the debt collector that they have investigated and verify the accuracy of their reporting, which is tantamount to debt verification, however not communicated directly to the consumer, as requred under FDCPA 809(b).
