In a Bulletin and Report, the CFPB warned furnishers of consumer data information to consumer reporting agencies that they must comply with FCRA’s re-investigation requirements. And, in a shot across the bow, the CFPB stated that merely deleting a trade-line does not by itself comply with FCRA’s reinvestigation requirements. The CFPB warned:
A furnisher should not assume that it ceases to be a furnisher with respect to an item that a consumer disputes simply because it directs the CRA to delete that item. Also, whether an investigation is reasonable depends on the circumstances, but furnishers should not assume that simply deleting that item will generally constitute a reasonable investigation.