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The OC signed for the CMRRR on 11/5, exactly 30 days ago and I have not received a response. Are they required to have a response back to me in 30 days, or is having their response dated no more than 30 days good enough? My next step is a CFPB complaint but I am trying to determine whether I need to contemplate standard mail delivery times for a response that is dated today or before.
The FCRA did somewhat of a two-step when defining the period of response to a direct dispute.
It defined the period as being the same as that imposed on a CRA for reinvestigation of a dispute filed with the CRA.
The FCRA requres the CRA to conclude its reinvestigation within 30 days of filing of the dispute (unless new info was presented after initial filing of the dispute, which would then extend the period to 45 days).
They are then required to sent their Notice of Results of Reinvestigation within 5 business days after conclusion of their reinvestigation.
Thus, by inference, a furnisher has 30 days to complete their investigation, and five busniess days thereafter to mail their notice of results of their investigation.
Thirty plus five plus possible weekend days plus mailing time would be approx. 40'-45 days after receipt.
I would not file a formal complaint until at least that period of time has passed.
Thank you Robert. Exactly the clarity I was looking for.
Today is day 36 and still no response. I will wait until at least day 40 before I submit a complaint with the CFPB.