When a consumer disputes the completeness or accuracy of any information contained in his/her credit report, the consumer reporting agency (CRA) must conduct a "reinvestigation." The term "reinvestigation" is a statutory term under the Fair Credit Reporting Act (FCRA). If the reinvestigation reveals that the information is inaccurate or cannot be verified, the CRA must promptly delete the information. 15 U.S.C. § 1681i(a). Failure to conduct a reasonable reinvestigation violates the FCRA. Cushman v. Trans Union Corp., 115 F.3d 220, 223–24 (3d Cir.1997). The burden to conduct the reinvestigation is on the credit reporting agency. It cannot be shifted back to the consumer.

A credit reporting agency's reinvestigation obligation is to verify the accuracy of its original source of information. This duty may include going beyond the original source. Whether the credit reporting agency must go beyond the original source depends on a number of factors, including: (1) whether the consumer has alerted the CRA that the original source may be unreliable; (2) whether the CRA itself knows or should know that the original source is unreliable; and (3) the comparative costs of verifying the accuracy of the original sources versus the potential harm the inaccurate information may cause the consumer. Dixon-Rollins v. Experian Information Solutions, Inc., 753 F.Supp.2d 452 (2010).

As part of its reinvestigation, a consumer reporting agency must provide the original source of derogatory information with notice of the consumer's dispute. 15 U.S.C. § 1681i(a) (2). The notice “shall include all relevant information regarding the dispute that the agency has received from the consumer.” Id. Moreover, the Third Circuit Court of Appeals recently confirmed that a reasonable reinvestigation “must mean more than simply ... making only a cursory investigation into the reliability of information that is reported to potential creditors.” Cortez v. Trans Union, LLC, 617 F.3d 688, 713 (3d Cir.2010) (citing Cushman, 115 F.3d at 225).