Credit Scores and Credit Reports, by Evan Hendricks

Chapter 9

Reinvestigations (or not)

Investigate — v. To observe or study by close
examination and systematic inquiry. Systematic — adj.
Marked by thoroughness and regularity.

-- Webster's New Collegiate Dictionary

For the past several years, a tension has been building over the adequacy of reinvestigations being performed both by consumer reporting agencies (CRAs) and credit grantors in response to consumer disputes.

During the 2003 Congressional debate over the FCRA Amendments, privacy experts and consumer advocates repeatedly criticized both CRAs and credit grantors for failing to live up to their duties to reinvestigate. Rather than truly investigate, critics charged, the CRAs and credit grantors, upon receiving a dispute, prefer only to compare the disputed information to what they previously reported. If the disputed information is the same as what the credit grantors previously furnished to the CRA, then they "verify" it.

This process has caused many a maddening moment for consumers who dispute what they know to be inaccurate information, but are told by the CRA the information has been "verified." It also has drawn the attention of the law's overseers, the FTC and State Attorneys General (AGs), and its creator, Congress. Between 1991-92, either the FTC or State AGs reached agreements with each of the three major CRAs that included requirements to improve reinvestigations. In 1996, Congress likewise amended the FCRA to put a greater duty on CRAs and on credit grantors to conduct adequate reinvestigations, and to strengthen consumers' rights if they failed to do so. (See Chapter 10)

Despite these new requirements, the 2003 Congressional hearings confirmed that the CRAs and credit grantors continued to run an automated system of data-comparison which did not comport with the normal definition of "reinvestigate." Many critics argued that CRAs and credit grantors were not complying with the law. A few courts have agreed in individual cases.

In the 2003 Amendments (FACT Act) to the FCRA, Congress again sought to bolster consumers' rights to accuracy. It gave consumers the right to dispute errors directly to the credit grantor when they were the source of the error. (However, consumers should still file disputes with the CRAs to maximize legal options). Congress also enhanced the accuracy standards for credit grantors, requiring that they not report inaccurate data that they "know or reasonably should know" as opposed to the old, weaker standard, of "knows or consciously avoids knowing." Finally, Congress directed the federal banking regulatory agencies by December 1, 2004 to publish rules and guidance to improve furnisher accuracy. (They missed the deadline.) In addition, the FTC must conduct a multi-year study on accuracy.

It will take some time to determine what impact these changes will have, and whether they will prompt CRAs and credit grantors to conduct true reinvestigations upon receiving disputes.

To understand how far they have to go, it is necessary to examine the systems that have been in place in the years leading up to the 2003 Amendments. Let's begin by looking at the situation from what might be the perspectives of CRAs.

Rising Volume

For starters, the volume of disputes has risen dramatically. Various depositions of CRA representatives have produced estimates that CRAs can receive 5,000 to 25,000 consumer disputes per day, with 7,000-10,000 being the more typical range. The CRAs staff their dispute departments at levels where dispute handlers are expected to handle between 10-12 consumer disputes per hour. Because each consumer dispute averages three disputed items, this means that the CRA employee only has a few minutes to handle each disputed item (Do the math: 12 consumer disputes with three items on each dispute, or 12 x 3 = 36 disputed items; divide the 36 disputed items by 60 minutes = 1.66 minutes to handle each dispute item).

This volume naturally poses tremendous challenges for CRAs and credit grantors. An important factor is that dispute handling is purely an added expense, or "cost center," and is not generally seen as enhancing revenues. Thus, they generally prefer to handle disputes as cheaply as possible. Possibly the greatest risk to handling disputes too cheaply, and not adequately, is that the CRA or credit grantor could get hit with a large fine or jury award for non-compliance with the FCRA. But since such fines or jury awards have been few and far between, the risk, from the CRAs' and credit grantors' viewpoints, probably does not seem that great.

Credit Repair Volume

Another factor is that a significant percentage of disputes come from credit repair agencies, some of which attempt to get accurate-but-negative information removed from consumers' credit reports by flooding the system with disputes. There have been no independent studies that provide reliable numbers about credit repair volume. In his 2003 testimony before Congress, Trans Union CEO Harry Gambill estimated that 35 percent of disputes came from credit repair agencies. Another industry source placed it closer to 25 percent. Even if that range is accurate, it means that about 65-75 percent of disputes are from individual consumers and presumably legitimate. It is difficult to believe that CRAs and credit grantors can adequately investigate thousands of legitimate disputes a day using the current system.

To deal with this volume, the CRAs and furnishers have set up an automated system for exchanging messages when consumers dispute inaccuracies in their credit reports. The system is called E-OSCAR. In other words, market forces, i.e., the high volume of disputes and the cost of human resources, have prompted the financial services industry to cut corners when it comes to FCRA reinvestigations.

In another cost-cutting move, all CRAs are outsourcing dispute handling to overseas call centers. Equifax was first to make this move, outsourcing to dispute processing to Jamaica.¹¹² In late 2003, Experian and Trans Union were preparing to experiment with centers in India or the Philippines.¹¹³

Exchanging Codes

As we saw in Chapter 5, "How To Dispute Errors," the dispute form urges consumers to categorize their dispute, e.g., "Not Mine," or "Paid In Full." The CRAs typically have a two-digit code for each category.¹¹⁴

¹¹² Prepared statement of Leonard Bennett, "Fair Credit Reporting Act: How it Functions for Consumers and the Economy," before the House Subcommittees on Financial Institution and on Consumer Credit, House Committee on Financial Services, June 4, 2004; http://financialservices.house.gov/hearings.asp?formmode=detail&hearing=225
¹¹³ Privacy Times, Sept. 12, 2003 Volume 23 No. 17; also see Lazarus, David, "Credit Agencies Sending Our Files Abroad," San Francisco Chronicle, Nov. 7, 2003.
¹¹⁴ Or, a two-symbol, alpha-numeric code, i.e., "A4" means "not mine"

When a consumer writes to the CRA to dispute inaccurate information in his or her credit report, the CRA typically reduces the consumer's dispute to the corresponding two-digit code and transmits it to the furnisher. The furnisher typically will only check to see if the information it furnished before is the same information it has on file. If it is the same, then the furnisher "verifies" the previously furnished information.

It's conceivable that this system might be an appropriate and effective response to the tactics of credit repair agencies. Some credit repair specialists advertise that they can "remove" negative information from consumers' credit reports (even if that negative information is accurate). They typically try to flood the system with disputes in the hope that CRAs and credit grantors won't meet the 30-day deadline reinvestigation deadline, thereby forcing them to delete negative information that they didn't have time to verify. (See Chapter 11)

But again, it is difficult to believe that CRAs and credit grantors can adequately investigate thousands of legitimate disputes a day using the current system. According to the CDIA, the trade group representing CRAs, 46% of disputes were verified as reported; 27% were modified/updated per furnisher's instructions; 10.5% had data deleted per furnisher's instructions; 16% had data deleted due to statutory time limit.¹¹⁵

Not True, But 'Verified'

This process is particularly frustrating for consumers who are victims of mixed files and/or identity theft. For instance, Judy Thomas, a Klamath Falls, Oregon realtor in 1996 first disputed information in her credit report that actually related to the credit problems of Judith Upton, of Stevenson, Washington.

¹¹⁵ Statement of Richard J. Hillman Director, Financial Markets, General Accounting Office, Before the Senate Committee on Banking, Housing, and Urban Affairs, July 31, 2003 www.gao.gov/new.items/d031036t.pdf

Trans Union said it would be removed. But in 1999, Ms. Thomas discovered the information had been reinserted, so she disputed it again. This time, the furnishers "verified" because the information disputed by Thomas was precisely the same information about Ms. Upton that the credit grantors had furnished before. In other words, their automated comparison about "then-and-now" showed no discrepancy, so neither the credit grantor nor Trans Union saw any reason to change it.

Carol Fleischer was a Michigan resident who sued after Trans Union failed to unmixed her file, which included a negative Capital One account that was no hers.

Regina Sorenson, a Trans Union consumer affairs manager, testified that this two-dimensional exchange of messages between itself and Capital One was the extent of TU's "investigation." Here's how she described it when questioned by Fleischer's co-counsel, David Szwak:

Szwak - Now you sent [Capital One] a CDV (consumer dispute verification) and the response came back verified as to the name and the Social Security number; is that true?

Sorenson - Verified means the account information was accurately reported and they also verified name and Social Security number.

Szwak - And as a result, you all completed your investigation by updating it to show it had been verified by Capital One and leaving Capital One on Ms. Fleischer's credit report; is that true?

Sorenson - Yes, it is.

Szwak - Other than sending the CDV to the six furnishers, what else did Trans Union do to investigate Ms. Fleischer's complaints?

Sorenson - Nothing else.¹¹⁶

¹¹⁶ Deposition of Regina Sorenson, in Carol Fleischer v. Trans Union, et al. U.S. District Court for the Eastern District of Michigan (Southern Div); Case No. CV 02-71301.

As an 18-year-old, Jason Turner, of Alabama, did not think Equifax had a file on him. But when he applied for his first Capital One card, Equifax returned a credit report showing he had several delinquent accounts, one of which went bad supposedly when Jason was 14 years old. Naturally, he was rejected for the credit card. He was also rejected for an auto loan.

Young Jason eventually learned that every time he applied for credit, Equifax would create a report that included the bad history of a much older Jason Turner. This happened because the names were identical, and because 7-out-of-the-9 digits of their SSNs were identical. (The older Jason never lived in Alabama.) The Equifax algorithm assumed the two Jasons were the same person, and disregarded the major discrepancies in ages, as well as dates of birth and addresses.

Both Jason and his mother tried to convince Equifax that the derogatory accounts did not belong to young Jason. But they ran into a wall. First, the Equifax dispute handlers apparently did not know that the partial match of the two Jason Turners' SSNs kept causing the older Jason's bad payment history to be dumped onto young Jason's report when he applied for credit.

In response to the dispute, Equifax Celestina Spencer queried the system using young Jason's SSN. But this query used a "search logic" requiring an exact match of all nine digits of the SSN. Ironically, Spencer was unable to find any accounts that belonged to young Jason: by using the stricter, 9-for-9 digit SSN match, Spencer ensured that the older Jason Turner's derogatory information was not mixed into Young Jason's credit report. Thus, Spencer told Jason's mother that Jason "did not have a file."¹¹⁷

¹¹⁷ Deposition of Celestina Spencer, Jason Turner v. Equifax Credit Information Services, Inc.: U.S. District Court for the Northern District of Alabama (Southern Div.); Case No. CV 02-J-0787-S.

Mrs. Turner tried to explain that Equifax disclosed an inaccurate file to Capital One and to the auto dealer, and that it needed to be corrected. But as Ms. Spencer later said in a deposition, "Nothing was being done because there was nothing to do... I wanted her [Mrs. Turner] to understand that it was not his credit file for me to do anything to."

In other words, Equifax was telling Capital One that Jason was a deadbeat, but telling his mother that it "did not have a file" on him. When confronted with this discrepancy, Ms. Spencer, the Equifax dispute handler, said:

"There should not have been a file, but there could have been because his addresses are here [and] because they would have keyed in his name and his addresses. Our system — I don't know how to answer that question. He is there, but he is not there."

After months of trying, Jason's mother finally convinced Ms. Spencer to conduct a reinvestigation. So what did she do? Ms. Spencer sent a standard "CDV," or Consumer Dispute Verification, to Capital One. But the CDV listed the older Jason Turner's SSN, date-of-birth, and derogatory trade lines, with the younger Jason's address. Capital One then "verified" the information.

An exchange between Christopher Kittell, a Mississippi attorney who represented Jason Turner, and Alicia Fluellen, senior manager for Equifax's Office of Consumer Affairs, confirmed that the CDV exchange was the Equifax investigation:

Kittell: Are they're other methods of investigation despite the CDV or other than the CDV?

Fluellen: No, we send out a CDV.

Kittell: That's it. If it comes back one way, good for the consumer, if it comes back agreeing with the creditor, then not agreeing with the consumer, then it stays?

Fluellen: Correct.

Kittell: Basically, Equifax takes the word of the creditor, whatever the creditor says is what Equifax does?

Fluellen: Yeah.¹¹⁸

Of course, many felt this was a huge breakdown in how the system was supposed to work. In the 1996 Amendments, Congress increased duties on CRAs to ensure they would investigate disputes. The amendments required that CRAs forward disputes to creditors within five days, and then complete the reinvestigation within 30 days. If not completed by the 30-day deadline, the law required that the disputed data be deleted. In an effort to add depth to reinvestigations, the Amendments required CRAs to "provide all relevant information" concerning a consumer dispute to the furnishers. That meant that if a consumer attached payment statements or letters to his dispute, the CRA was supposed to send it to the creditor. Moreover, the Amendments for the first time placed a duty on creditors to reinvestigate, but generally only imposed liability for failing to do so when they received consumer disputes from the CRA.

Despite these changes in the law, there was abundant evidence that the old ways continued right up to the point that this book went to press.¹¹⁹ Many believed this two-dimensional message exchange does not amount to a true reinvestigation. (Webster's New Collegiate Dictionary defines "investigate" as "to observe or study by close examination and systematic inquiry." One of the definitions of "systematic" is "marked by thoroughness and regularity.")

¹¹⁸ Deposition of Alicia Fluellen, Jason Turner v. Equifax Credit Info. Serv., Inc.: U.S. Dist. Ct., Northern Dist. of Alabama; Case No. CV 02-J-0787-S. Equifax designated Fluellen as its "30(b)(6)" witness, meaning she was representing the company and describing its policies.
¹¹⁹ March 2005

Credit Grantors

As noted earlier, major credit card companies have seen their dispute volume rise in recent years. They too generally try to cope with the volume by using an automated message exchange.

Pamela Tuskey, a manager in Capital One's credit report dispute department, confirmed in a deposition with Ian Lyngklip, a Michigan attorney, that in October 2001, Capital One received about 1,000 disputes per day. By May 2002, it had grown to 2,000 disputes per day. By the spring of 2003, the official said the number of disputes had grown to 4,000 per day. Some of the increased volume was attributed to the boom in home buying and mortgage refinancing, when more and more consumers discovered the importance of their credit scores, she said.¹²⁰

Tuskey said her department's job was to "verify" disputed information that Capital One had reported to the CRAs. That meant her personnel would simply check the disputed information against the information in its system. If the two matched up, it was "verified."¹²¹

She said her department did not have ready access to original credit card applications or other primary documents that might come in handy for affirming that the consumer's dispute was well-founded. The pulling of paper files was considered "in-depth research," and was not handled by her department. Instead, "research" was conducted by a smaller committee in charge of "escalated" disputes. One example of an "escalated" dispute was an irate customer, or attorney, who directly wrote or called Capital One, she said.¹²²

¹²⁰ Deposition of Pamela Tuskey, in Carol Fleischer v. Trans Union, et al. U.S. District Court for the Eastern District of Michigan (Southern Div); Case No. CV 02-71301.
¹²¹ Id.
¹²² Id.

When Lyngklip asked Tuskey why her department did not do "in-depth research," she replied that sometime around February of 2000, representatives from Trans Union, Experian and Equifax each paid separate visits "to explain to my team how to more properly and more accurately work accounts."¹²³

"One of the questions that I had for them, as a manager," Tuskey continued, "was should we verify the accounts — and I even explained to them what my definition of verify is — which is, we pull up our system of record, in this case Unisys or Beast, we look at what the bureau has sent us on the ACDV. If there are any discrepancies, we make sure that what the bureau has mirrors exactly what we, as Capital One, have. That's verifying," Tuskey said.¹²⁴

Lyngklip: That was what you described to the representatives as verifying?

Tuskey: Yes.

Lyngklip: And what did they say in response to that?

Tuskey: Well, I actually followed that up with, 'Do you want us to do that, or do you want us to do things such as pull statements, etc., actually do the research which would involve CHIA?¹²⁵ And in each case, the bureau rep said, No, we want you to verify it. We want you to make our system look like your system. So that's what we've been doing.

However, in a mixed file or identity theft case, having the credit bureau's data "mirror" Capital One's data was not going to establish whether the information was accurate in the first place.

One thing that was missing from this equation was concern for the truth. After all, shouldn't the purpose of an "investigation" be to get to the truth? In fact, both CRA officials and credit grantor personnel have testified that it's not their job to arbitrate the truth. Look at this exchange between Lyngklip and Tuskey:

¹²³ Id.
¹²⁴ Id.
¹²⁵ CHIA is the system where Capital One stores applications and other primary documents

Lyngklip: For purposes of how you administer the FCRA, does the underlying truth of the matter enter into the decision? In other words, if the information in Cap One's system is not, in fact, true, is Cap One going to verify the data as accurate as long as it matches?

Tuskey: Not — if we — if we do not — I'm not quite sure if you're — are you — restate that question.

Lyngklip: Sure, I can do that. Cap One, as a matter of how it administers to the FCRA... and looks at the accuracy requirements, does not equate accuracy with truthfulness, what it does is it measures accuracy in terms of whether or not the data matches between what's in the credit reporting system and what's in Cap One's computer; is that a fair statement?...

Tuskey: So your, your — the way the question is posed to me makes it sound like I have to choose between whether I'm saying what my associates do is accurate or truthful but not both.

Lyngklip: Well, no, what I'm asking is this: Is it possible, is it possible that Cap One will verify information that is not, in fact, truthful?

Tuskey: There's a possibility of that. It certainly would not be done intentionally.¹²⁶

Is That All There Is?

Lyngklip asked if Tuskey's department ever did anything but check it own computers. "What about picking up the phone and calling up the person who is disputing the credit report?" Lyngklip asked. "It would seem to me that that would be a pretty good source of information to determine whether or not two individuals are the same person."

¹²⁶ Deposition of Tuskey, op. cit.

"No, my team does not have any direct contact with the cardholders," Tuskey replied. "Again, we're not a customer-contact center. That's not within the scope of our job."

Training also did not appear to be a priority.

Lyngklip: How did you find out about the procedures and in terms of how they come to their decision, and how did you find out about the mechanics of the credit dispute process?

Tuskey: I found out the way any new associate would find out. I had side-by-side training. At the time that we're looking into here, we had no formal policies or procedures, no written documentation. It was really all on-the-job training, so I became familiar by sitting with a veteran associate as well as a quality associate just like everybody else...

Lyngklip: This might sound like a silly question, and I don't mean to be flip at all, but who trained the first staff person? Do we know how those procedures were handed down and where they came from originally?

Tuskey: No. My guess, since everything had not been documented at all, my guess is it was just like oral history; you tell me and I'll tell the next person and the next person, and a lot of judgment calls going on.

Lyngklip: Now, that describes how the decision-making process is made in terms of whether or not a particular dispute will be resolved in favor of or against a consumer, what about the mechanics of navigating the screens? Is that something that's written down in training manuals or guides?

Tuskey: Now it is.

Lyngklip: Again, when was that implemented?

Tuskey: Three weeks ago.

Tuskey's deposition was taken May 21, 2003, some six years after the FCRA Amendments 1996 put a duty on Capital One and other creditors to report information accu-rately, and to investigate consumer disputes. A company source said that in light of the 2003 Amendments to the FCRA, Capital One was reviewing its credit reporting-related procedures.

MBNA

At MBNA, an "investigation" similarly consists of a comparison of the disputed data with information in its database, the Customer Information System (CIS). One of the first to delve into its practices was Leonard Bennett, a Newport News, Virginia attorney who represented Linda Johnson.

The lawsuit swirled around an MBNA MasterCard opened by plaintiff Linda Johnson's ex-husband, Edward Slater, in 1987 - four years before he married her. They had since divorced. Johnson said she was only an authorized user, which meant she was not responsible for paying the account. In December 2000, Slater filed for bankruptcy, and MBNA promptly removed his name from the account. That same month, MBNA contacted Johnson and informed her that she was responsible for the approximately $17,000 balance on the account. After obtaining copies of her credit report from Experian, Equifax, and Trans Union, Johnson disputed the MBNA account with each of them. Experian and Trans Union sent automated consumer dispute verifications (ACDVs) to MBNA specifically indicating Johnson's claim that she was not a co-obligor on the account.

MBNA agents responded by comparing the disputed data with the account information contained in MBNA's computerized Customer Information System (CIS). Since the two were identical, MBNA "verified" that the disputed information was correct. In other words, MBNA did nothing more than confirm that it indeed reported the original (inaccurate) data. The CRAs continued to report it on Johnson's credit report.

Tricia Furr, an MBNA credit reporting specialist, confirmed that MBNA's "Desktop Procedure" manual directs specialists to confirm a match of two out of three identifiers - name, address and/or SSN. Once a two-out-of-three match is established, MBNA can inform the CRA that the disputed information is "verified as reported." Ms. Furr said that MBNA's "reinvestigations" do not go beyond the information contained in its own CIS.¹²⁷

Furr: I looked at the balance that we have on CIS and the history of the account as compared to the trade line as opposed to what we had on our Customer Information screen...

Bennett: In performing the investigation and re-investigation of consumer disputes, once it receives an ACDV¹²⁸ from a credit reporting agency, when are MBNA's credit reporting specialists supposed to look beyond the Customer Information System for investigation? ...I am asking the practices and procedures now.

Furr: The Customer Information System is the only thing that we have to use for verification. So, there is no where else to look.

Bennett: Do you ever pull documents, like old statements, and check payments and credit card applications?

Furr: No, sir.

¹²⁷ The depositions of MBNA personnel were taken in the case, Linda Johnson v. MBNA America Bank, N.A., Slip Op. No. 3:02 cv 523, U.S. District Court For The Eastern District of Virginia (Richmond Division).
¹²⁸ The dispute form is known as an "ACDV," or Automated Consumer Dispute Verification Reading from MBNA's internal records, MBNA Vice President Edward Hughes quoted an MBNA employee's communication to a customer's attorney: "It would be up to (c)ard holder to prove MBNA was reporting wrong, not MBNA proving right."

Here Comes The Judge

In a sense, Hughes' statement proved to be wrong. Linda Johnson was one of the few consumers who sued and actually had the chance to tell her story to a jury. MBNA argued that it verification methods complied with the FCRA. The jury disagreed, and awarded Johnson $90,300.

Judge Richard Williams affirmed the jury verdict. "According to [MBNA], the duty to investigate means that any investigation is sufficient, no matter how cursory. Such a construction is illogical. There would be no point in having the statute, and the requirement of an investigation, if there was no qualitative component to the investigation. The statute itself does impose a qualitative component to the [MBNA's] negligence" Judge Williams said.¹²⁹

MBNA appealed Judge Williams' decision. But on February 11, 2004, a three-member panel of the U.S. Court of Appeals for the Fourth Circuit affirmed, finding that MBNA's standard response to consumer disputes did not amount to a true "reinvestigation" under the FCRA.

¹²⁹ Johnson v. MBNA, op. cit., bench ruling February 24, 2003

"MBNA argues that the language of � 1681s-2(b)(1)(A), requiring furnishers of credit information to 'conduct an investigation' regarding disputed information, imposes only a minimal duty on creditors to briefly review their records to determine whether the disputed information is correct," the panel wrote, in an opinion authored by Chief Judge William W. Wilkens. "Stated differently, MBNA contends that this provision does not contain any qualitative component that would allow courts or juries to assess whether the creditor's investigation was reasonable."¹³⁰

"The key term at issue here, 'investigation,' is defined [by the dictionary] as 'a detailed inquiry or systematic examination.' Thus, the plain meaning of 'investigation' clearly requires some degree of careful inquiry by creditors," he wrote.

Further, he said, the statute "uses the term 'investigation' in the context of articulating a creditor's duties in the consumer dispute process outlined by the FCRA. It would make little sense to conclude that, in creating a system intended to give consumers a means to dispute — and, ultimately, correct — inaccurate information on their credit reports, Congress used the term 'investigation' to include superficial, unreasonable inquiries by creditors. We therefore hold that � 1681s-2(b)(1) requires creditors, after receiving notice of a consumer dispute from a credit reporting agency, to conduct a reasonable investigation of their records to determine whether the disputed information can be verified."

MBNA also tried to argue that its investigation in Johnson's case was reasonable. But the court pointed to the specific nature of Johnson's dispute, and the testimony of MBNA agents that their investigation was primarily limited to (1) confirming that the name and address listed on the ACDVs were the same as the name and address contained in the Customer Information System, and (2) noting that the CIS contained a code indicating that Johnson was the sole responsible party on the account.

"The MBNA agents also testified that, in investigating consumer disputes generally, they do not look beyond the information contained in the CIS and never consult underlying documents such as account applications. Based on this evidence, a jury could reasonably conclude that MBNA acted unreasonably in failing to verify the accuracy of the information contained in the CIS," he wrote.

¹³⁰ Linda Johnson v. MBNA America Bank: CA-4 - No. 31-1235; Feb. 11, 2004

Richard Rubin, a Sante Fe, New Mexico attorney who argued the case for Johnson before the Fourth Circuit, noted that the panel adopted his position that had MBNA simply told the truth and stated that its investigation was inconclusive, the CRAs would have deleted the tradeline as required by the FCRA, and the litigation never would have occurred.

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