You disputed an item with Equifax, Experian, or TransUnion. Two months later, the bureau wrote back saying the account was "verified." The negative line is still on your report. Most consumers stop there.

The Fair Credit Reporting Act gives you one more move, and the bureau has 15 calendar days to answer it. The provision sits at 15 U.S.C. §1681i(a)(6)(B) and §1681i(a)(7), and it forces the bureau to describe how it actually verified the disputed item, including who they contacted at the furnisher and how to reach them. When the bureau cannot produce a real description, the item often comes off the report.

This is the method of verification request, often shortened to MOV.

What is a method of verification request under the FCRA?

A method of verification request is a consumer's statutory demand, under 15 U.S.C. §1681i(a)(6)(B), for the bureau to disclose the procedure it used to determine the accuracy and completeness of an item it claimed to verify in a reinvestigation. The bureau must provide a description of that procedure, plus the business name and address of any furnisher of information contacted in connection with the disputed item, and the telephone number of that furnisher if reasonably available.

The right is triggered after the bureau has already returned a "verified" or "verified as accurate" result on a dispute filed under §1681i(a)(1). It is a follow-up move, not a first dispute. The text of §1681i(a)(6)(B)(iii) requires the bureau's reinvestigation results notice to inform the consumer of this right. The notice rarely makes it conspicuous, and the right gets ignored as a result.

What the bureau owes is narrow but specific. A description of "the procedure used to determine the accuracy and completeness of the information." Not a copy of the underlying contract. Not the original signed application. The procedure. In practice, that means: who did you call, what did you ask, what did they say, and how did that satisfy you that the disputed entry was accurate.

How long do credit bureaus have to respond to an MOV request?

15 calendar days from the date the bureau receives the request, written into 15 U.S.C. §1681i(a)(7). The statute reads: "A consumer reporting agency shall provide to a consumer a description referred to in paragraph (6)(B)(iii) by not later than 15 days after receiving a request from the consumer for that description."

This 15-day clock is separate from and in addition to the 30-day reinvestigation deadline under §1681i(a)(1)(A). The 30-day window applies to the initial dispute. The 15-day window applies only to the MOV request that follows a "verified" result. A consumer can run both clocks in sequence. Dispute, wait 30 days, get a verification, send the MOV request, wait 15 days.

The deadline is calendar days, not business days. Mail and processing time eat into the window. Sending the request by certified mail with return receipt creates a clean record of the date the bureau received it, which is the date the 15-day clock starts.

Why does an MOV request often get the item deleted?

The bureaus rarely have a substantive description to provide, because most modern dispute investigations are processed through a system called e-OSCAR, where the bureau forwards a coded summary to the furnisher and the furnisher responds with a short coded answer. The CFPB's Spring 2022 Supervisory Highlights identified furnishers sending incorrect special comment codes on Automated Credit Dispute Verification (ACDV) forms, and credit-card furnishers that failed to conduct any investigation at all because of system errors, mistakenly classifying thousands of indirect disputes as frivolous.

Consumer Financial Protection Circular 2022-07 reinforced that a "reasonable investigation" under the FCRA must be substantive. The CFPB stated that a consumer reporting agency or furnisher "must reasonably investigate the dispute unless they have reasonably determined that the dispute is frivolous." Confirmation alone is not the same as investigation.

When a consumer asks for the description of the procedure used, the bureau's options narrow. Either it produces a real account of who it contacted, what was asked, and what was reviewed, or it admits the verification was thinner than the result implied. Many bureaus respond with a generic letter that does not actually describe a procedure. Under §1681i(a)(5)(A), if the disputed information cannot be verified, the bureau must "promptly delete that item of information from the file of the consumer, or modify that item of information, as appropriate." A description-deficient response gives the consumer a documented basis to demand deletion.

This is why the request works. Not because the law has a hidden delete button. Because the bureaus' verification process, when forced into the open, often does not stand up.

What goes in a method of verification letter?

A complete MOV request identifies the disputed item, references the bureau's prior verification result, demands the §1681i(a)(6)(B)(iii) description by name, and sets the 15-day clock. Keep it short and statutory.

A workable MOV letter includes:

  1. Your full name, current and prior addresses for the past two years, and date of birth.
  2. The disputed account, identified by the creditor name and the partial account number as it appears on your credit report.
  3. A reference to your original dispute date and the bureau's verification response date.
  4. A direct citation: "I am requesting, under 15 U.S.C. §1681i(a)(6)(B)(iii) and §1681i(a)(7), the description of the procedure used to determine the accuracy and completeness of the disputed information, including the business name and address of any furnisher of information contacted, and the telephone number of that furnisher if reasonably available."
  5. A statement that you expect a response within 15 days of the bureau's receipt of the letter.

Send the letter by certified mail with return receipt to the bureau's dispute address. Keep a copy of the signed letter, the certified-mail receipt, and the green return-receipt card. That bundle is what proves the 15-day clock started.

What's your next move if the bureau ignores it or the description is inadequate?

If the bureau fails to respond within 15 days, or the response does not actually describe the procedure used, the consumer can file a complaint with the Consumer Financial Protection Bureau and, in clearer cases, has a private right of action under 15 U.S.C. §1681n (willful noncompliance) and §1681o (negligent noncompliance).

A CFPB complaint is filed through the agency's portal at consumerfinance.gov/complaint. The bureau receives the complaint and is generally required to respond on the record. Documented MOV failures sit well in this format because they are concrete and date-stamped.

For the private right of action, willful violations under §1681n carry actual or statutory damages and attorney's fees. Negligent violations under §1681o carry actual damages and attorney's fees. This is not legal advice. A consumer who believes the bureau's response is a clear FCRA violation should consult an attorney who handles consumer-protection cases.

The MOV request is quiet but powerful precisely because it forces the bureau to choose. Describe the procedure, or delete the item. The statute does not give a third option.

Sources

  1. Legal Information Institute, Cornell Law School. 15 U.S.C. §1681i — Fair Credit Reporting Act, procedure in case of disputed accuracy.
  2. Consumer Financial Protection Bureau. "Consumer Financial Protection Circular 2022-07: Reasonable investigation of consumer reporting disputes." November 2022.
  3. Consumer Financial Protection Bureau. "Supervisory Highlights, Issue 26, Spring 2022." April 2022.
  4. Legal Information Institute, Cornell Law School. 15 U.S.C. §1681n — civil liability for willful noncompliance.
  5. Legal Information Institute, Cornell Law School. 15 U.S.C. §1681o — civil liability for negligent noncompliance.
  6. Consumer Financial Protection Bureau. "Submit a complaint."