Module 4: How To Interpret Credit Bureau Responses

After round 1 dispute letters have been mailed to the bureaus there is a 30 – 45 day waiting period during which they must respond. Once they respond the information that they have sent needs to be reviewed. 

In this next section, we will discuss reviewing consumer credit reports and the information that is reported there. 

Each bureau should send a new copy of its credit report when they respond to disputes. Their response will also contain a status message with the result of the dispute. This result should be added to the dispute tracker or your personal notes. 

The letter below is one example of a typical response letter from the credit bureaus. In this letter two separate events occurred: 

1. New personal information was added or updated.

2. Two accounts were successfully removed via the dispute process. 

Reviewing New Credit Reports

If using online credit report monitoring, there will likely be a 30 day waiting period from the last time you checked your credit reports for it to update. However, the bureaus should also send you a new paper copy of your credit report with each dispute they answer. 

When reviewing these new credit reports, consumers should compare the information in each consumer report against the other two consumer reports, as well as against any personal records or recollections. If information is substantially complete and accurate across all sources, then it should be reported the same way (or very similar) throughout each of these documents.

After a dispute has been filed, consumers should check the bureaus responses carefully to see if the information has been corrected. Is it still negative? Is it listed as “verified”, or was the item “deleted” from the credit report by the bureau? 

Compare each data point from each account as it is reported on each credit report. 

Does the information on the updated credit reports match your personal recollection or personal records? If you are repairing credit for a client does the information from the credit bureaus line up with their documentation or recollection?

Credit repair operators do not need to try to determine fault or liability for their clients. Even if their client allegedly owes a collector money, that information still needs to be reported accurately, and if it isn’t, then the law says it must be removed. 

As an example, if a client has a negative account on their credit reports that claims they owe $10,000, but their records indicate they owe $9,900, then there is a discrepancy in the data somewhere. That means the account is not being reported accurately, and that it needs to be removed from the client’s credit profile until that data can be reconciled. 

It’s not the accounts themselves that credit repair operators focus their time on for their clients, it’s the accuracy of the details associated with those accounts. 

Credit repair providers focus on the question of whether or not the information that the credit bureau is reporting is factually accurate when compared to other reliable information sources, including client opinion. 

If a credit repair client receives a notice from a collector that says they owe $12,000, but the client believes they owe $10,000, the client has a right to know how that extra $2,000 was calculated. To those that “pull” this consumer’s credit report it will appear that this account is more severe than it actually is. An additional $2,000 error (errors like this always favor the corporations and never the individual consumer) could easily translate into further, real-world financial complications and monetary loss by making the client appear riskier than they should during credit based decisions, including some forms of employment and many opportunities for promotion. 

Data Furnishers Aren’t Automatically Right

Just because a company claims a consumer owes additional money doesn’t make it automatically so. There are many subtle differences in each client’s accounts that could sway that determination one way or the other. 

Many life events such as divorce, crime, identity theft, fraud and others occur millions of times each year and most of these errors find their way into consumer credit data in one form or another.  

By asking the bureaus to verify the information they are reporting, through following an established dispute process, we are asking them to legally commit to a data set. Once they do this, we can use the information they provide, which is usually insufficient or different than what is on the report itself, as proof that the account should be removed. 

In one more example let’s assume that a credit repair client is having issues with a debt collector. The credit repair company reviews the balance that the debt collector is claiming is owed against what the consumer believes he or she owes. Both of those numbers are compared to the information that the credit bureau is reporting. Statistics heavily suggest that the information will not be the same across these three sources, which again means that a data discrepancy is occurring and a credit repair client should not be the one forced to absorb all of the negative consequence of inaccurate credit reporting. With the evidence from this example, a complaint can be filed to force the removal of this information from the client’s credit reports.

If, after submitting a dispute, the credit bureaus verify that the information is correct but you or your client know that it is wrong and that it should be deleted, you will simply need to continue your dispute process further in order to remove these negative accounts. Variations in any of the details of the accounts on your credit reports is grounds for continued dispute filing. 

If a consumer finds that any of the following information does not exactly match their own documentation or is otherwise incorrect, then it is grounds for continued disputing. 

Examples of data points on consumer’s credit reports that can be disputed include the following:

Company name(s)

Company addresses

Amounts owed

Date of account opening

Date of account last paid

Date of account status

Account status

Number of days delinquent

Original creditor(s)

Court jurisdiction

and others…

Every single data point on each of the accounts on all 3 of the consumer’s credit reports needs to be looked at closely for accuracy. If it is not accurate or the result of initial dispute filing is unacceptable then it should be disputed again. 

Aside from negative information on the new copies of credit reports that are issued by the bureaus with their dispute responses, there are several sections that do not contain negative information that also need to be reviewed to ensure they are accurate. 

The bureaus can be directed to correct any of the following information through the dispute process. 

Each section contains important information that will be checked by employers, landlords, utility companies, cell phone providers, and, of course, potential creditors and many others for an adult consumer’s entire life. Consumers should make sure this information is correct to prevent any future problems from arising due to inconsistent or inaccurate information.

Credit Repair Is A Lifelong Process

Credits reports from the three agencies each look slightly different but are generally composed of sections similar to these:

Personal Profile

This section contains a consumer’s personal information, such as legal name, current and previous addresses, employment history, and birth date.

Credit Summary

This is a snapshot of a consumer’s credit, including how many accounts have been opened in the consumer’s name and their total balance(s). Reported delinquencies will be listed here as well.

Public Records

Most consumers don’t have any public records listed in this section, however they are very common. Mistakes in this area are also fairly common and need to be disputed immediately. This type of information includes bankruptcy, tax liens, court records, judgement, and child support.

Credit Inquiries

Any company that a consumer gives permission to review their credit file (called a hard inquiry) will be listed here for two years. More than three inquiries listed in this section can potentially lower a credit score, but not very much. If consumers see companies listed in this section that they do not recognize they need to be removed.

Personally checking your own credit (such as through a paid provider or credit monitoring service like referenced above) will not result in a hard inquiry or have any effect on your credit. The same is true for your clients as long as they are signing up themselves. Those types of inquiries are known as soft inquiries and don’t affect consumer credit scores. Typical listings in this section include lenders and potential or former employers and landlords.

Account History

This is the specific account information for all accounts opened in a consumer’s name that are being reported to a credit reporting agency. This information can be positive or negative and collectively has the biggest impact on credit ratings. A large amount of inaccurate information can be found on some people’s credit reports in this section.

Positive information will remain on your report indefinitely, while negative information will remain for seven to ten years from the date that the account was closed or the date the consumer last made a payment on or possibly acknowledged the alleged debt.

The contact information for all the companies that are providing information (data furnishers) about the consumer will also be found in this section. These addresses are suitable for sending dispute letters to. It is always preferable to mail disputes certified or delivery confirmation via USPS. 

Filing disputes online is not recommended. 

The bureaus recommend that consumers file online and claim it will greatly speed up the dispute process. What they are really shooting for is to trick consumers into filing online because that is how they get them to agree to their terms of service, tricking consumers into agreeing to arbitration which waives many of the powerful consumer protections that the law provides and this course utilizes to force bureau compliance.

Credit Report Information Should Be Reviewed Several Times Against Multiple Other Data Sources For Accuracy

The sections above will comprise the majority of information on a consumer credit reports. As stated before, they should be reviewed very carefully. Special attention should be devoted to the alleged amounts that the consumer owes, the payment dates, and the names of the companies that are reporting the negative information.

Those who are undertaking credit repair for themselves or as a paid provider for a client should take note of whether or not negative accounts are being reported to the bureaus by the original creditor or a debt collector. Account creation dates should be accurate across all three reports and should also correspond to original creditor information you or your client has, as well as the debt validation or verification that was received.

Every single data point that is being reported should be accurate and compared across all three credit reports. By making notations of what is believed to be incorrect and then reconciling this information with other records, incorrect and harmful data can be removed from credit reports. 

What if you don’t have any records?

Having records or “proof” is not a requirement for individual consumers to dispute any information in their credit report. Companies that catalog and report information about consumers for profit on a huge scale, however, are bound by such laws.

If you do not have any documentation to support you or your clients’ disputes, it is ok to proceed. 

Gather all of the information that is available, including client opinion, and compare it with what is on the credit reports. By disputing information, we are asking the bureaus to investigate these accounts, and then send us proof of their investigation. If they cannot or do not comply as required, then the information must be removed. 

It can sometimes be a point of evidence in favor of the consumer if the three credit bureaus each list the same account but with different origination dates, different amounts owed, or other differing information that does not seem to be accurate, which is very common.

By taking detailed notes of everything in you or your client’s paperwork that seems inaccurate you will develop a thorough body of evidence supporting your claim that the information is inaccurate and should be removed.

A Winning Credit Bureau Response

Once the credit bureau dispute process has begun by sending initial letters to the credit bureaus, responses will usually be received within about 30 – 45 days.

Many times when a response is received from the bureau, it will say that they have investigated the dispute and determined that the account is valid and that it will remain on the consumer’s credit report. What this usually means in real world application is that an automated computer system from the credit bureau sent a message to another automated computer system owned by the data furnisher asking to verify that the information it is furnishing about the consumer is valid.

The most common example of this is e-Oscar. The service they provide to the bureaus is known as “Automated Credit Dispute Verifications (ACDVs)”. 

If we consider the hypothetical example of a consumer who has a $5,000 collection account being reported to their Experian credit report, then we know that a collection agency is telling Experian that the consumer owes $5,000, and that Experian is telling the world by publishing it onto this consumer’s credit report.

Since the credit bureau is reporting that this consumer owes $5,000, they are just parroting the information given to them by the data furnisher, in this case a collector. The bureau’s “investigation” after a consumer files a dispute simply involves the bureau contacting the collector and asking the collector to VERIFY ITS OWN INFORMATION. There is not a real investigation.

The bureau is simply asking the collector to verify the accuracy of its own information—which could be highly variable because a debt collector is sometimes allowed to adjust the amount of debt it is reporting by charging interest on top of the amount the consumer allegedly owes the original creditor.

What Does A Win Look Like?

It’s complicated. 

Recently a student disputed several items on their TransUnion credit report. They also updated their personal information at the same time. TransUnion responded by updating the student’s personal information (you update personal information by filing a dispute as noted above) and reporting that two collection accounts were deleted.

This is an example of both the good and bad of the credit reporting system at work. On one hand, the system worked correctly. Disputes were filed with the bureaus, and the bureaus recognized that the information being reported in the accounts was outdated and deleted them.

It sounds like a good thing that the bureaus corrected and deleted these two accounts, however the main reason it was easy to have these accounts removed without further processing is because they were both almost ten years old.

That means that even though the bureaus corrected their mistakes by deleting the inaccurate information they had been reporting once they were caught, they had already been violating the student’s rights by reporting the negative information for THREE YEARS after the date it was supposed to legally and automatically fall off of her credit reports.

The credit reporting system has always operated under the premise that it is OK for corporations and others to report damaging, invalid information onto consumer credit reports until they are caught with almost no repercussions aside from the most gregarious of infractions. 

How much money had having irrelevant and outdated credit information cost this student over the previous 3 years? 

That is a hard number to calculate, but she did purchase a car during that time, so statistics say that unless she refinances her loan that negative credit will cost her an additional $10,000 over the life of her auto loan on average.

One transaction. $10,000 of extra expense.

Of course, according to Forbes, the cost of having bad credit can actually DOUBLE the cost of a consumer’s vehicle purchase. 

Do you think that most potential credit repair clients would be willing to pay legitimate, honest credit repair companies a small monthly fee for a few months to put this much cash back into their pockets?

Credit repair operators save their clients thousands of dollars and a tremendous amount of time and stress. 

An Ethical Credit Repair Service Can Save Clients Thousands

Home mortgages are much more costly for those with bad credit and negative items should definitely be processed off of the credit report prior to applying for a home loan. 

Many times, as is the case for our student above, consumers are only made aware of the inaccurate information on their credit reports after they have already suffered an adverse event. Even though the student above was granted an auto loan when she applied (at a very high interest rate), she was denied a financing option for elective weight loss surgery sometime later, after her credit score should have actually gone up a little.  

This caused her to check her credit report, realize that inaccurate information was impacting her life, and begin the credit repair process. After the negative entries were removed and her personal information was updated she was able to get the procedure a few months later, and has now lost over 100 lbs.

This is just another example of how having great credit can really open up the doors to the most amazing opportunities life has to offer for you and your family or clients. 

It also illustrates how bad credit can slam those doors shut until it is repaired.

METHOD OF VERIFICATION REQUEST

The next step in the dispute process is to wait 35 -50 days for the bureaus to respond to the round 1 dispute letters. 

Why 35 – 50 days and not 30 – 45? The bureaus have 30 or 45 days to complete their investigation of filed disputes, and another 5 business days to send the results to the consumer. 

When their responses are received, if the disputed items remain, send the credit bureau another letter and request what is called “method of verification” proof. 

Consumers must act fast, as this must be done within 15 days from the conclusion of the initial dispute. The best way to do it is to immediately send out this letter the same day you receive your dispute results from the bureaus listing every account that was not deleted.

This method of verification is a right that all consumers possess to request that the credit bureau provide the methods that they used to complete the investigation into a consumer’s dispute. 

Often times, the credit bureaus cannot or do not comply with method of verification requests, leaving the door open for consumers to continue the dispute process by filing a complaint against the bureau due to their inaccurate record-keeping practices that are not in line with current consumer protection standards. 

Download the letter from the module 4 “Method Of Verification Request Template” folder on the left. There are pre-addressed letters for Experian, Equifax and TransUnion. Customize these letters with your information and then send them USPS with tracking. Make sure you take a picture of all mailings with your phone and keep track of all dates that you send information and the date the bureaus receive it. You will need this documentation soon so take the time to be thorough. 

The method of verification protection that consumer law provides is very powerful, and by following the steps outlined in this course consumers are typically able to initiate and complete highly successful dispute processes for a variety of issues.

(Date)

(Your Name)

(Your Address)

(Your City, State, Zip Code)

TransUnion Consumer Solutions

P.O. Box 2000

Chester, PA 19022-2000

Dear Sir or Madam:

I previously disputed items which you verified as accurate.

Please provide me with your method of verification or I am going to file a complaint against your company with the CFPB. Specifically, provide me with the following information in accordance with the FCRA:

• Copies of any documents you used to make your decision, including electronic correspondence of all types
• A copy of all information you sent to the data furnisher during your investigation, including transcripts of all telephonic conversations and any information you received from the data furnisher
• The name, job title and contact information of the individual(s) you contacted at the data furnisher
• The name, job title and contact information of all employees within your organization who played any part in handling this dispute

Obviously your continued reporting of this inaccurate information is causing me financial distress.

Please provide me with the above information and delete these accounts from your report immediately.

If I have not heard from you within 30 days from the date you receive this certified letter I will be filing a complaint against you, initiating other legal action, or both.

Thank you in advance for your help in correcting these errors.

(Your Signature)

(Your Name)

Encl: Credit Report (also list any additional information you will be enclosing)

(Date)

(Your Name)

(Your Address)

(Your City, State, Zip Code)

Equifax Information Services LLC.

P.O. Box 740256

Atlanta, GA 30374-0256

Dear Sir or Madam:

I previously disputed items which you verified as accurate.

Please provide me with your method of verification or I am going to file a complaint against your company with the CFPB. Specifically, provide me with the following information in accordance with the FCRA:

• Copies of any documents you used to make your decision, including electronic correspondence of all types
• A copy of all information you sent to the data furnisher during your investigation, including transcripts of all telephonic conversations and any information you received from the data furnisher
• The name, job title and contact information of the individual(s) you contacted at the data furnisher
• The name, job title and contact information of all employees within your organization who played any part in handling this dispute

Obviously your continued reporting of this inaccurate information is causing me financial distress.

Please provide me with the above information and delete these accounts from your report immediately.

If I have not heard from you within 30 days from the date you receive this certified letter I will be filing a complaint against you, initiating other legal action, or both.

Thank you in advance for your help in correcting these errors.

(Your Signature)

(Your Name)

Encl: Credit Report (also list any additional information you will be enclosing)

(Date)

(Your Name)

(Your Address)

(Your City, State, Zip Code)

Experian National Consumer Assistance Center

P.O. Box 4500

Allen, TX 75013

Dear Sir or Madam:

I previously disputed items which you verified as accurate.

Please provide me with your method of verification or I am going to file a complaint against your company with the CFPB. Specifically, provide me with the following information in accordance with the FCRA:

• Copies of any documents you used to make your decision, including electronic correspondence of all types
• A copy of all information you sent to the data furnisher during your investigation, including transcripts of all telephonic conversations and any information you received from the data furnisher
• The name, job title and contact information of the individual(s) you contacted at the data furnisher
• The name, job title and contact information of all employees within your organization who played any part in handling this dispute

Obviously your continued reporting of this inaccurate information is causing me financial distress.

Please provide me with the above information and delete these accounts from your report immediately.

If I have not heard from you within 30 days from the date you receive this certified letter I will be filing a complaint against you, initiating other legal action, or both.

Thank you in advance for your help in correcting these errors.

(Your Signature)

(Your Name)

Encl: Credit Report (also list any additional information you will be enclosing)

Module 4 References

1. “If a credit reporting error is corrected, how long will it take before I find out the results?”; https://www.consumerfinance.gov/ask-cfpb/if-a-credit-reporting-error-is-corrected-how-long-will-it-take-before-i-find-out-the-results-en-1339/

2.  “This is how bad credit can double the cost of your next car”; https://www.forbes.com/sites/startswithabang/2018/05/01/this-is-how-bad-credit-can-double-the-cost-of-your-next-car/#57669ea537da 

3. “Automated Credit Dispute Verifications (ACDVs) “; https://www.e-oscar.org/