FCRA Section 623 explained: what data furnishers must do
FCRA Section 623 sets the rules for furnishers — the banks, lenders, and collectors who report your accounts to the bureaus. They must report accurately, investigate disputes the bureau forwards to them, correct or delete information they can't verify, and stop reporting data they know is wrong. Section 623 is why a dispute reaches the source of the error, not just the bureau.
Who counts as a furnisher
A "furnisher" is any company that supplies information about you to the credit bureaus — your credit card issuer, auto lender, mortgage servicer, student loan servicer, and debt collectors all furnish data. Section 623 of the Fair Credit Reporting Act is the part of the law that governs what these companies have to do. While Section 611 covers the bureaus' duties, Section 623 covers the source of the data.
What Section 623 requires
Section 623 puts several duties on furnishers:
- Report accurately. A furnisher can't report information it knows, or has reason to believe, is inaccurate.
- Investigate disputes. When a bureau forwards a dispute, the furnisher must investigate it, review the relevant information, and report back.
- Correct and update. If the furnisher finds the information is incomplete or wrong, it has to fix it with every bureau it reported to.
- Stop reporting known errors. Once a furnisher knows an item is inaccurate, it can't keep reporting it as if it were correct.
Direct vs. indirect disputes
There are two ways a dispute reaches a furnisher. An indirect dispute goes to the credit bureau, which forwards it to the furnisher — this is the most common path and triggers the furnisher's investigation duty. A direct dispute goes straight to the furnisher itself. Both are valid, and sometimes using both is the most effective approach for a stubborn error.
The accuracy and notice duties
Two Section 623 duties matter especially for disputes. First, if a furnisher reports an account that's in dispute, it generally has to note that the consumer disputes it. Second, furnishers must report the correct date of first delinquency on negative accounts — the date that controls when an item ages off your report. A wrong date of first delinquency is a common, fixable Section 623 violation.
Why this matters for your disputes
Section 623 is the reason a dispute can reach the company that actually created the error, not just the bureau displaying it. When CreditRefresh drafts a dispute, it's relying on these furnisher duties — the obligation to investigate, to correct, and to stop reporting information that can't be verified. That's what turns a dispute from a request into a legal obligation the furnisher has to answer.