On January 7, 2025, the CFPB filed a lawsuit against Experian alleging that Experian violated FCRA by failing to properly conduct reinvestigations of disputed information in consumer credit files; failing to delete inaccurate, incomplete, or unverified information in consumer credit files; failing to provide adequate written notice to consumers of the results of its reinvestigations; failing to prevent the improper reinsertion of previously deleted information from consumer credit files; and failing to follow reasonable procedures to assure maximum possible accuracy of the credit information Experian reports on consumers. In addition, the complaint alleges that Experian committed unfair acts or practices in violation of the Consumer Financial Protection Act of 2010 by (1) failing to convey consumers’ disputes to furnishers fully and accurately, and instead distorting, truncating, and mischaracterizing consumers’ disputes; (2) relying excessively on furnishers to resolve disputes, routinely doing nothing more than sending the dispute to a furnisher and implementing the furnisher’s response, despite having evidence of that furnisher’s unreliability; and (3) improperly reinserting tradelines into consumer credit reports due to its practice of failing to adequately match newly reported tradelines to tradelines that were previously deleted as a result of a dispute if the subsequent furnishing was from a new furnisher. The Bureau seeks, among other things, to bring Experian into compliance with the law, consumer redress, and the imposition of civil money penalties.
What is e-OSCAR?
e-OSCAR is the “Online Solution for Complete and Accurate Reporting” system through which the consumer reporting industry (consumer reporting agencies and data furnishers) resolve disputes brought by consumers concerning the accuracy of information maintained in their credit files.
When a consumer contacts a consumer reporting agency with a dispute, the agency transmits an electronic form called an ACDV through e-OSCAR to the data furnisher. The data furnisher responds to the consumer’s dispute by returning the ACDV through e-OSCAR. For example, if a consumer disputes the accuracy of the payment history on their Citibank credit card to Trans Union, Trans Union will send an ACDV to Citibank informing Citibank of the consumer’s dispute and Citibank will respond to that dispute by returning the ACDV to Trans Union.
e-OSCAR also allows data furnishers to correct or delete a consumer’s account by sending an electronic form called an AUD. When a consumer contacts a data furnisher and requests a change of information that has been previously reported, the data furnisher researches the account. If the data furnisher verifies that the account information in question needs to be modified, the company will use the e-OSCAR system to complete an AUD.
What is an ACDV?
What is an ACDV?
The largest search we find on our page concerns ACDV’s. So, what is an ACDV?
An ACDV is an Automated Credit Dispute Verification form that is used by the credit reporting agencies to communicate consumer disputes to lenders and collection agencies.
ACDVs are transmitted to furnishers via an electronic system known as the "E-OSCAR" system, which is an automated system that enables furnishers and credit reporting agencies (CRA’s) to create and respond to consumer credit history disputes.
The ACDV process tracks and manages an ACDV initiated by a credit reporting agency on behalf of a consumer and routes it to the appropriate furnisher.
The furnisher then, returns the ACDV to the initiating CRA with the updated information (if any) relating to the consumer's credit history.
In responding to an ACDV, a furnisher informs the CRA’s if the disputed information is "Verified" or if the disputed information should be "Changed" or if the disputed item of information should be "Deleted". To do this the furnisher literally checks a box.
Once checked, this will instruct the CRA that all information about the disputed tradeline is, in fact, accurate and that no changes should be made. If a furnisher chooses to change information, it will check a box called "Change Data As Shown" and then will input changes into the various fields of information that need to be changed. Whenever a furnisher directs a CRA to change information on a consumer’s credit file, that furnisher affirms to the CRA that it has made the same changes to its own systems. This affirmation is made by the furnisher on the form used to process the dispute.
More About How Trans Union Processes Consumer Disputes - E-OSCAR and the ACDV Process
In 2005, a Trans Union ("TU") representative testified as follows regarding TU's procedures to conduct reinvestigations when a consumer disputes inaccurate information on their credit report: In general, when TU receives a dispute from a consumer, TU investigates the dispute using one of two systems developed for the purpose of processing and tracking disputes: the mail Consumer Dispute Verification process (“CDV”) and; the electronic Automated Consumer Dispute Verification process (“ACDV”) utilized in the instant matter.
How does Trans Union process consumer disputes?
In general, when Trans Union receives a dispute from a consumer, Trans Union investigates the dispute using one of two systems developed for the purpose of processing and tracking disputes, the Consumer Dispute Verification process (“CDV”) and the Automated Consumer Dispute Verification process (“ACDV”). Through the ACDV process, Trans Union contacts the furnisher of the disputed credit information and, via an automated process, asks the furnisher to verify that the indicative (e.g., name, social security number, address, date of birth, etc.) information on the consumer matches the indicative information maintained in the furnisher’s records and is associated with the particular account being disputed. Trans Union also asks the furnisher to verify the accuracy of the account information, e.g. account balance, payment history, credit limit, etc., being reported to Trans Union by the furnisher.
If the furnisher verifies that the reported information is correct, Trans Union updates the information on the consumer's credit file and notifies the consumer of that fact. If the furnisher reports that the information is inaccurate or can no longer be verified, or if the creditor does not respond within the required time, Trans Union deletes the information from the consumer's credit file and notifies the consumer that the information has been deleted. Trans Union may employ additional procedures depending on the precise dispute involved and the circumstances of the case.