Reasonable investigation
The investigation must be reasonable under the circumstances — we verify that all relevant information forwarded by the bureau was reviewed, including free-text dispute, account record, and prior ACDVs.
FurnisherProof assembles a litigation-defensible investigation file for every consumer dispute — ACDV and direct — with field-level tradeline reconciliation, Metro 2 response, and a trained human reviewer signing each verify/modify/delete decision. Checked against the letter of FCRA §1681s-2(b) before release.
Every U.S. business that reports to a credit bureau has a non-delegable legal duty to conduct a reasonable investigation of each consumer dispute it receives. Miss one of the required investigation steps, skip a relevant record, or fail to document the process — and the furnisher faces FCRA liability, regulatory enforcement, and settlements that have quadrupled to $45–50K.
Most furnishers treat disputes as a data-entry task: confirm/modify/delete in a dropdown. But the law treats it as a fact-finding investigation whose adequacy is judged after the fact in court. That gap between what the workflow captures and what a reasonable investigation requires is where liability hides.
FurnisherProof exists to close that gap with a single, exhaustive standard applied identically to every dispute.
We do not summarize the law and hope. Every investigation is scored against a versioned rule pack tied to the exact text of FCRA §1681s-2(b). These are the provisions each file is held to.
The investigation must be reasonable under the circumstances — we verify that all relevant information forwarded by the bureau was reviewed, including free-text dispute, account record, and prior ACDVs.
Every piece of information the consumer dispute verification contains is reviewed and reconciled against the furnisher's system of record — no cherry-picking.
The furnisher must correct any inaccuracy and report the results to all bureaus. We draft the Metro 2 response and evidence memo for each dispute.
The response must be made within the applicable 30-day (or 45-day) window. Our deterministic calendar gates enforce the deadline before release.
If the investigation results in modification or deletion, the furnisher must notify all bureaus that received the data. We include the notification checklist.
For direct disputes, the furnisher must investigate if the consumer provides sufficient information. We verify the dispute meets the statutory sufficiency threshold.
AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A trained FCRA reviewer signs every release. That order is never reversed.
Upload your ACDV queue or direct disputes. We return a free completeness read: which investigation elements and records you already have, and which are missing.
As your authorized agent, we retrieve the account record, application, payment ledger, notes, and prior ACDVs from your system of record and build the evidence log.
The investigation memo and Metro 2 response are drafted from your validated data and the §1681s-2(b) rule pack into field-locked templates — no legal opinions, no invented facts.
The dispute text is reconciled to the account record field-by-field; the 30-day window is verified; the evidence checklist is resolved; SCRA and identity-theft flags are screened. Any failure blocks release.
A trained FCRA reviewer reviews the exception queue, makes the verify/modify/delete judgment, and signs the release. Legal-dispute and identity-theft items route to attorney review first.
You receive the investigation file: evidence memo, Metro 2 response, evidence log, timeline, and certified-mail packet — ready for the furnisher to submit under its own name.
The deliverable is completeness itself — every statutory investigation element and record accounted for or explicitly exception-coded. Nothing is left implicit.
The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a statutory requirement.
We prepare documentation and run searches as your clerical agent. We never contact the consumer, give legal advice, or make the final reporting decision.
Simple, predictable, and aligned with an investigation standard — not a cut of any recovery.
Start with a free Dispute Gap Scan. Send your ACDV queue or direct disputes and we'll return a completeness read against every subsection of §1681s-2(b).
Documentation-completeness service · not legal advice · the furnisher makes every reporting decision.