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Does my bank need to respond to a duplicate dispute from a credit repair organization that my bank has already responded directly to a consumer about?

If my bank receives a direct dispute from a consumer about information the bank has reported to a consumer reporting agency and responded in accordance with Regulation V requirements, does it need to respond to the same dispute that a credit repair organization repeatedly submits on that customer’s behalf?

The bank need not investigate, but it must provide a frivolousness notice. Section 1022.43(b)(2) of Regulation V excludes from the requirement to investigate and respond to direct disputes any dispute that the furnisher reasonably believes is ”submitted by, is prepared on behalf of the consumer by, or is submitted on a form supplied to the consumer by, a credit repair organization…” However, §1022.43(f)(2) requires furnishers to notify consumers that a dispute is frivolous or irrelevant, and under §1022.43(f)(1)(ii), a dispute is frivolous or irrelevant if it is a direct dispute that the furnisher is not required to investigate (e.g., direct disputes from credit repair organizations). Thus, the bank need not investigate the direct dispute from the credit repair organization, but it must notify the consumer of the determination no later than five days after making the determination. (January 2018)

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