Statutes are usually couched in terms of requiements, not absence of requirements, and I know of no statute that specifies the negative.
A few considerations you might use....
First, and foremost, in order to report to a CRA, a party must have a reporting agreement with that CRA.
That is a private business contract to which no party is mandated to establish.
Second, even if a party has a reporting contract with a CRA, the FCRA does not mandate that all information related to the account must be reported.
The basic reporting requirement of the FCRA is section 623(a)(2), which states that any information must not knowingly by inaccurate when reported, not that all accurate information must be reported, or even that it must be accurate when reported. They cannot report information with knowledge of its inaccuracy.
I thihk the best you wlll be able to prove the absence of a requirement to report is by the lack of any statutory requirement to do so.
