In Ritchie v. Lease Finance Group, LLC, et. al., 2017 WL 2963462, at *2 (C.A.2 (N.Y.), 2017), the Court of Appeals for the Second Circuit said that it was the substance of the reinvestigation, not the time spent on it, that matters under the FCRA.
Ritchie argues that when Experian notified defendants that Ritchie’s signature was disputed, FCRA required them to “conduct an investigation with respect to the disputed information,” “review all relevant information provided,” and “report the results of the investigation to [Experian].” 15 U.S.C. § 1681s-2(b)(1). They did all those things. That they did so in as little as two minutes does not mean that they violated the statute.