FCRA Requirements Checklist for Credit Data Furnishers & Lenders

A practical guide to responsible credit reporting and dispute handling.

Staying ahead of FCRA requirements requires more than policy—it’s about execution. From ensuring permissible use to handling disputes and furnishing accurate data, every detail matters. With 35 years of industry leadership, Bridgeforce has helped clients turn compliance into a competitive advantage through expert strategies and real-world solutions. Use this checklist to elevate your credit reporting practices and reduce risk with confidence.

FCRA Requirements Checklist for Your Competitive Advantage

1. Using Credit Reports (Permissible Purpose)

• Only Pull for Legal Reasons  –  You must have a permissible purpose, such as a credit application, account review, employment screening (with consent), or underwriting insurance, to access someone’s credit report. Pulling a report without a valid reason isn’t just a mistake, it’s illegal.
• No Inappropriate Access  –  Never obtain a credit report under false pretenses or use it for marketing. Misusing reports, even once, can lead to legal and reputational consequences.
• Match the Right Person  –  Make sure you’re pulling the correct consumer’s report. Avoid relying on “possible match” or “name-only” data. Mistakes here can lead to mixed files, which are a serious compliance issue and have a downstream impact for consumers.
• Mind State Laws Too  –  Some states have extra restrictions, especially for employment use. For example, California and New York only allow credit reports for specific roles. Always check for any local rules that go beyond the federal law.
• Give Proper Adverse Action Notices  –  If a decision (such as denying credit or employment) is based in whole or in part on a credit report, you must notify the consumer. The notice must include the National Credit Reporting Agency’s (CRA) name, the right to dispute, and how to obtain a free copy of the report.

2. Furnishing Data to Credit Bureaus

• Accuracy is Everything  –  Furnishers must report accurate, fact-based data. Common issues include outdated balances, incorrect account status, or inaccurate payment information. Even small mistakes can harm consumers and lead to enforcement.
• Fix Known Errors  –  If you discover that furnished data is inaccurate, whether through an audit, complaint, or dispute, you must correct it across all CRAs. Knowingly reporting inaccurate data is a direct FCRA violation.
• Report DOFD for Delinquent Accounts  –  When reporting delinquent, charged off or collection accounts, always include the Date of First Delinquency. This field drives how long negative info stays on a credit report. Skipping it can result in outdated or illegal reporting and is an immediate red flag for regulators and auditors.
• Mark Disputes Properly  –  If a consumer directly disputes an account, flag it as “in dispute” with the CRAs until it’s resolved. If the info changes, update it across the board. Failure to do so risks the error reappearing later.
• Handle Identity Theft Correctly  –  If notified that data you reported is due to ID theft, don’t re-report it unless you’ve verified with 100% confidence that it’s accurate. Have procedures to deal with fraud reports and block or remove affected data as needed.
• Have Written Policies and Staff Training  –  Furnishers are required to maintain written policies that ensure the accuracy and integrity of their data. This includes internal controls, employee training, and regular updates to reflect changes in systems or rules.
• Regulators Are Watching  –  State Attorneys General and the CFPB are heavily focused on credit reporting accuracy. Regularly audit your data and resolve problems quickly to avoid enforcement actions.

3. Handling Disputes

• Investigate All CRA Disputes  –  When a CRA sends you a dispute, you must investigate thoroughly. A thorough investigation includes reviewing all supporting documents, not just summary codes. Ignoring or brushing off disputes is a major compliance failure.
• Take Direct Disputes Seriously  –  Consumers can also send disputes directly to you. Unless they fall into a narrow list of exceptions (like repeat or clearly frivolous claims), you need to investigate and respond within 30 days.
• Stick to the Timelines  –  Dispute investigations must be completed within 30 days. Failing to meet deadlines can result in data being removed and could trigger regulatory scrutiny.
• Look at Everything Provided  –  When investigating, review all information the consumer or CRA sent, not just codes. This includes letters, images, PDFs or anything else that may be relevant.
• Fix or Delete Inaccurate Info  –  If the data is wrong and you can’t fix it, delete it and notify the CRAs accordingly. Do not re-report the bad info in your next cycle. Also, make sure to correct your system of record.
• Keep Good Records  –  Document every dispute: what came in, what you did, how you responded. This helps during audits and protects you if issues come up later.
• Expect Oversight  –  Both the CFPB and state AGs actively monitor dispute handling. Failures, like not fixing errors or ignoring valid claims, have led to millions in fines and required operational overhauls.

Strengthen Your Credit Reporting with a Proactive Compliance Approach with Bridgeforce

Compliance with FCRA requirements isn’t just about avoiding penalties, it’s about protecting consumers and maintaining trust. Lenders and data furnishers play a critical role in making sure credit reports are fair, accurate, and responsibly used. Clear policies, proper training, and a consumer-first approach go a long way.

Whether you’re building new credit reporting processes, improving furnishing accuracy or addressing gaps from past exams, Bridgeforce is your partner for meeting FCRA requirements. Let’s get you started with a solution tailored to your risk and readiness.

Contact us today.