You can also use the Credit Repair Dispute – Tracking Worksheet

Credit Repair Process – See below for our 10 Steps Dispute formula and tying everything together.

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Strategy – See Below for the steps you should take:

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).

The strategy is that credit bureaus fall short in the matter and usually won’t be able to verify items. You can send your disputes via certified mail or fax with confirmation, In some instance, one can call the bureaus challenging accounts but must organized for this to occur.

Submitting the Dispute

Step one in any credit report dispute process begins when you, the credit repair consultant on behalf of your client, notify the appropriate party that they disagree with an item on your credit report(s). The dispute is most commonly submitted to the credit reporting agencies (CRAs) themselves (Equifax, Trans Union, and Experian) and can be initiated via mail, online, by fax, or over the phone. You should not use the online method and you will learn this within the training program.  However, many consumers do not realize that you can also initiate a dispute directly with the company who supplied the allegedly inaccurate information to the credit reporting agencies – aka the “data furnisher.” Additionally, if you have already filed a dispute with the credit reporting agencies directly you also have the right to file a concurrent dispute with the Consumer Financial Protection Bureau (CFPB).  Use the McCarthy Law Firm Dispute Hand-book to be help you build your client’s case as you will see in tying is all together.

“In Dispute”

Whenever an item is disputed in a credit reports with the credit reporting agencies they are required by the FCRA to mark the item in question as “in dispute” on your credit reports; mortgage companies don’t like to see this on your credit report. If you initiated your dispute directly with the data furnisher then they are required themselves to notify all 3 credit reporting agencies that the item is being challenged and must be marked as “in dispute.” In order to add the “in dispute” notation to an item on your credit reports a 2-character Compliance Condition Code, the “XB” code to be exact, is appended to the item in question. When the “XB” code is attached the account will appear on your credit reports with a statement which reads something along the lines of “Consumer disputes, investigation in process.”

The Investigation of The Claim

If you initiated the dispute with a credit reporting agency directly then the next step of the dispute process occurs when the CRA takes over and the actual “investigation” of the claim begins. First, the entire dispute is homogenized into a 3-digit code, a code that will be used to communicate your dispute with the data furnisher. There are several of these dispute codes but most disputes revolving around the consumer claiming the account isn’t theirs, the balance is incorrect, or the account was never late.

e-Oscar

The CRAs use an online system known as e-Oscar (Online Solution for Complete and Accurate Reporting) to facilitate the handling of the millions of disputes they receive from consumers every year. First, an ACDV form (Automated Consumer/Credit Dispute Verification) is filled out with the 3-digit code used to describe your dispute and sent to the data furnisher via the e-Oscar system. The data furnisher is tasked with the responsibility of looking into the claim and either verifying the account as accurate or instructing the CRA to update or delete the account. The same ACDV form will be used to detail the data furnisher’s findings and will be sent back to the CRA, again via e-Oscar.

The Results

Once the CRA receives a response from the data furnisher the client’s credit report will be updated. If the account was verified as being reported accurately then the only changes that will take place are the “XB” code being removed from your report and the “date reported” updated to the then current date. However, if the data furnisher agrees with your dispute then the account would be either updated to reflect different information or deleted from your report entirely. Additionally, if the data furnisher failed to respond to the CRA within the time allowed under the FCRA then the item in question would be deleted due to the lack of response. Regardless of the outcome, the CRA is required to send you the results of your dispute once the process has been completed.

We just provided you the process. Here are so more tips. 

UPDATE:Credit Consultants can now or soon will be able to submit disputes with Credit Monitoring Services and Obtaining Credit Information instantly on clients using Credit Karma or Privacy Guard.

Many of the large credit repair company can see exactly what is on their client’s credit report on the phone. This is because they have back end access to a credit monitoring services like credit karma. They can collect information from their clients and have direct information as to what is on their credit report on the fly. You can do the same by creating a credit karma account for your clients or obtain the password to access their already created credit karma account. The best part this is FREE.

With this in mind, you are able to perform direct dispute using these service and results are extremely positive. Please keep in mind that you must keep track of all online disputes with this organization to have a paper trail.

The process is this. You find out if the client has a credit karma account. If not, create one for them while they are on the phone and you can see exactly what is in their credit report instantly and have a general idea of their credit score. Then you can determine how you can help. This is such an excellent way to services you client and really get on top of their issues in a hurry

Also

1. It is not a good to get your FREE report from AnnualCreditReport.com. the reason, it gives the credit bureau up to 45 days instead of 30 to respond to disputes.
2. Forced Arbitration: Please note that when you purchase a credit report for the credit bureau directly, you will see an arbitration agreement that will prevent you from suing with a jury trial.Be Sure To Opt Out of Binding Arbitration Clause within 30 to 60 days of receiving a credit report from a credit bureau. You will find an opt out letter here

Written Format of Video:

Once you obtained copies of your client’s credit report and scores here are some steps you should follow: 
Please NOTE that credit scores are not calculated once a months as most believe, they are calculated at the time a client obtains their scores so in other words, they are calculated on the fly. 

NOTICE: You may be nervous to handle your first case and feel lost at first. We totally understand this and we are here for you.

We are noticing that one CAN dispute a hosts of items in one detailed dispute letter on the first try. YES we know the manual stated to dispute a few items at a time. However, we are seeing a slight change in this approach. Our CRA insiders are sharing that computer generated dispute software letters often will NOT do this effectively and why this approach gets pass filters. This is a way to weed out credit repair companies. Therefore good ole fashion typed detailed letters with explanations of why this items is incorrect…. will do the trick. Then at the end to wrap up the letter stating that these items are damaging your financial reputations and must be removed or updated at once.  Use the sample letters but update them to be more detailed with explanations. Details and evidence works!!! It takes more time but effective. The best part, this can separate you from larger credit repair firms or those using software to get extremely better results. Results means more clients.  The best dispute letter is when you can catch the Furnisher or Credit Bureau in a violation and an item and it will surely come off. 

Therefore, Just write a detailed dispute letter and challenge everything you feel is incomplete or inaccurate with explanation and evidence if you have it. Then once you receive your response from the credit bureau, you can deal with each individual item that was not deleted off the credit report.

PLEASE NOTE: THIS ONLY WORKS IF ITEMS HAVE NEVER BEEN DISPUTED BEFORE WHEN OBTAINING A CLIENT’S CREDIT REPORT. THIS IS WHY IT IS VERY IMPORTANT TO ASK A CLIENT IF ANYTHING HAS BEEN DISPUTED BEFORE IN THEIR FILE BEFORE. CREDIT BUREAUS HAVE COPIES OF PREVIOUS DISPUTES AND IF THEY DO NOT ALIGNED WITH WHAT IS BEING SAID NOW, YOU WILL NOT BE ABLE TO SUE BECAUSE YOU LIED ABOUT WHY AN ACCOUNT WAS INACCURATE OR INCOMPLETE. 

NOTE: It is important to know that if you falsely dispute negative information such saying that an account is NOT your client and it is their account, this can create legal problems for you and your company. It can also send you to jail. You can assist your clients without making or sending false disputes. The key is to help them reach their goal instead of making false promises or claims.

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Tying It All together: What to do first?

The Interview Process (Building a Case)

NOTE: Make sure that you client is a good candidate for Credit Repair Services. For example, if they are not financially able to pay all of their bills on time or do not have income, they are usually not a good candidate for credit repair services. If someone comes to you stating that I need to “Start repairing my credit” the first question you should ask is if they are caught up on all bills and have been paying them on time for at least 3 to 6 months. If not, THEY ARE NOT a good candidate and should only come to you after they are financially sound to pay their bills on time.

IMPORTANT: If a client is seeking a mortgage as their goal, it is important to understand how any action that you take could affect them, from settling collection debts to waking up old collections accounts. Any collection account over 4 years old, according to the FCRA the collector cannot send you any letters or call you. It is considered harassment; if they do reach out to you, it is consider a fair Debt collection violation and Telephone Consumer Protection Act. However, If you contact them by mail or fax, it can start the collection procedures all over again. Nothing in the act prohibits you from speaking with them verbally. Bu when collections accounts are paid after four years they are re-aged. It is important to negotiate and make verbally settlement. There are ways to settle in conjunction with a mortgage underwriter to do this that will NOT affect the score and help your client close their mortgage loan. Reach out to a credithelpdesk consultant for more details.

If they are a good candidate, then you will follow the next steps.

1. Just ask the client what are their goals or is there anything they are attempting to purchase that requires the use of their credit. Ask if they have ever used a credit repair company to dispute any items before or have they personally disputed any items before. This is a very important question for the sake of consistency and to build your case. If a dispute is different than previous ones, the credit bureau will have proof that you have lied previously to them and it will hurt your case. .
2. Then make sure you obtain your client’s credit reports and scores; never take their word on what is on their credit report. Say to them that you understand and that you will take a look to see how you can help. We like using MyFICO.com to pull credit reports however, clients can get a free copy and have to pay for their scores with annualcreditreport.com We like MyFico because they will already do the analysis for you and you won’t have to figure out why a client score is low. They will provide suggestions on how to increase the score and you can follow that process. Even though clients can have the same information, they won’t understand it as you will. Especially when you will have the Credit Score Manual as you guide.
3. Once you get the credit report, often the services you used to pull them will tell you where the client is having problems.
4. Evaluate the report and list all negative items that is affecting their credit. You can use the Credit Restoration Preliminary Form.
5. Collect your Credit Report Analysis or Audit Fee. $99 – $250. This fee for service rendered and no advice. You will audit their credit report and provide an analysis of what you found. You will start the interview process with the client going line by line on the credit report asking your client about everything from names, address to accounts.
6. ASK YOUR client about each negative item(s) within the credit report and what happened. Take their word for each item because you are building a case for them incase you discover violations where they are able to sue. This also protects you from a regulator that may try to accuse you of making up lies and sending in false disputes. NEVER lie on your dispute letter, we will cover this later.
7. But in evaluating the report FIRST VERIFY and Check to see if there are any recent past due accounts. If they are, this client is NOT a good fit for repair until they are caught up on their bills and have been current for at least 3 months. If you see all accounts are paid up to date and there is only one account past due, find out the problem and maybe this can be resolved.
8. Check to see if anything is outdated on the report meaning over 7 years or 10 years in case of a bankruptcy as well as If they are outdated, it will be easy to write a dispute letter to point this out and have it removed. Check for collections and revolving accounts because these are hurting their scores the most.
9. Check for the missing dates, missing amounts, last date of payment activity or when the last time the furnisher reported to the credit bureau. This is an important credit repair tool. Sometimes one may get a client to pay an account that hasn’t reported to the credit bureau within the last 6 1/2 years and that one payment will start the 7 years clock ticking again. Make sure you notice this so that you can advise your client to wait it out until the account is outdated.
10. Again, check for personal information that is incorrect. It may be a good idea to challenge outdated and incorrect personal information first but since you will be sending a detailed letter in the beginning, you can skip disputing this first; unless you have another strategy in mind.
11. Next you must figure out what is affecting their credit scores from what’s keeping them from reaching that goal and again using services like MYFICO or other monitoring services to obtain their credit will assist in this area. Also the credit report will show what is negative upfront. Write down these accounts or mark them directly on the credit report that you printed out and this where you will start coming up with your strategy. (NOTE THESE ARE PRIVATE DOCUMENTS AND IF YOU ARE PRINTING YOUR CLIENT’S REPORT, MAKE SURE THEY ARE NOT AVAILABLE FOR ANYONE TO STEAL THEIR IDENTITY.

Nuances regarding The Credit Report

Mortgages and Car loans inquires within a 30 day period are combined and consider as one. FICO does not count all of them separate. Credit inquires will hurt so make sure that you client DO NOT apply for any credit period during the credit repair process and really they should stop until their credit issues has been resolved. Also check for collection accounts that are under two years old and open resolving accounts.

The Dispute Process

1. Again, circle all of the inaccurate accounts you are disputing on the actual credit report and you can send it along with your dispute letter and make reference to the circled accounts. Give detailed explanations on each account disputed, why it is inaccurate or incomplete without admitting guilt, and why is should be removed. Example: “XXZ shows that I was late twice in month two and eight however, my records show that I paid this account on time promptly as agreed, I am being injured and according to federal law can be awarded damages. Therefore, please certify and attest that you have conducted the proper investigation and have this item remove at once. The months showing me late were actually paid on time and here is the proof.” Show them the payment activity of that month and here is why. Often a report will show a payment late but sometimes get the month wrong and you can show that that month was paid on the due date and posted by going online and getting that payment date history and all history must be wiped away. It works on occasions when you may have been late. Showing proof is amazingly powerful and gets things deleted. The more details provided the best chance for a thorough investigation.
2. When you start challenging accounts. Look for closed negative accounts with zero balances, first since they maybe not be verifiable. Open account are usually easily verifiable. It is also best to start with old closed accounts.

The 10 Step Dispute Formula

This is the step you should take with each client from start to closing their file. It’s a formula that works for all inaccurate and incomplete accounts. Remember that you are building a case for your client and auguring their position regarding the negative items on their account. You should know what steps you are going to take with that client from start to finish. Do not spend forever on a client’s file and you need to know when to close their file. On a personal note, so many that charge monthly only are creating an environment that is more advantageous to the credit repair company than the client. We at CCA really feel that consultants should consider dual method: the pay-per-deletion method in the beginning and monthly method after the second round of dispute and this will resolve this issue. The key is to increase the score as fast as you can in the beginning and when it requires more work, move them to a monthly method. Therefore, you can get many items removed to help your client reach their goal and able to close the file of this client quicker. During the cool off period because it best to wait 30 days after each challenge, you will get paid on your success of getting the results for your client.  Now here is the formula.

1. First look for violations based on the 13 common FCRA errors on the credit report we provide here and if they are there, pass them directly over to the law firm we have listed for you to sue the credit bureau. Remember the credit gets one opportunity to correct an error.
2. If they are not there, you will start your dispute process with the credit bureau. Use the McCarthy Law Firm Dispute Hand-book to be help you build your client’s case.
3. Did they respond? Keep in mind that you have to depend on your client to provide this information and sometimes they lose mail. Therefore, you can send a reminder alerting them they it was not received. I would fax this reminder.
4. If they respond, you must ask for their method of verification. The bureau must respond with the furnisher’s information: 15 U.S. Code § 1681g – Disclosures to consumers

The question is what to do if NOT.

After you have done these steps here is the formula for each client.

5. Remember that the credit bureau is governed by regulators and a business too. Therefore you can file a complaint and should do so for all of the below at the same time on behalf of your client using the failure of the Disclosures to consumer clause of the FCRA

Consumer Financial Protection Bureau CFPB https://www.consumerfinance.gov/complaint/getting-started/

File a Complaint to the Federal Attorney General’s office

http://www.ncdoj.gov/Consumer/2-2-12-File-a-Complaint.aspx

The Better Business Bureau in the state that they reside.

https://www.bbb.org/consumer-complaints/file-a-complaint/get-started

6. Contact a FCRA attorney. Because you have prepared a case for your client from the beginning, you will be able to share with them what is your argument. They will either say that you have a case or not.
7. If there is not case, you can send one more round of dispute on behalf of your client but this time dispute them online, via fax and mail at the same time.
8. If no response, you can try a cool down period for 90 days and restart the process from start to finish.
9. It is time to close the client file and provide them the reason. Then educate them on methods of rebuilding their credit.
10. If things do not go as the customer planned, they may take action against you. This is why we believe the pay-per-deletion method in the beginning is best. Because they could sue you. You can place your client on a client progress monitoring plan where they stay under your umbrella being accountable to you in reaching their credit score goal. You will reach out to them monthly regarding to review their progress. You will charge a nominal monthly fee for this service.

More Tips:

You can open an account with Letter Streams to mail all of your credit disputes.

If you get stuck, just ask us what you should do next here in the help desk and will help. You can upload a scan image too if you need us to take a look at what you are seeing on their report.  If you are having problems posting a message, just send us an email at help@credithelpdesk.org and we will still respond. Please include a phone number in case a consultant can’t respond in writing but could do so via phone. This sometimes happens for those who have purchased live phone coaching.

Now for the Nuances of the credit repair process we will repeat some things here with a little more information: 

2. First STEP: What is their goal? Mortgage, Car, (Bank Card can be obtained via a secured card). Never promise to clean up their credit report. See if you can work from an established goal; this will make you an even more effective credit consultant.
3. If they are seeking a car loan, then you should approach the credit repair process from that goal. Read this https://credithelpdesk.org/auto-enhanced-score/
4. If their goal is to obtain a Mortgage, this is a different process. You need to know: ‘when are they ready to buy?” Will it be a FHA or conventional loan? Also If it is soon then read https://credithelpdesk.org/more-on-rapid-rescore/. If time is not a major issue, you can take a long-term approach to raise their scores to optimum levels.
5. Once you know the goal you must see how their credit scores are affecting this goal. How many points they need to obtaining a mortgage e.g. 680 and some programs can work with lower scores.
6. What is affecting the score? There are what if’ simulators you can use to ascertain the dispute process: https://credithelpdesk.org/kb/credit-score-what-if-simulator/
7. Your attack should be from these levels. You may have to attack it with the creditors first in some cases or settle in others. The trick is understand procedures and attack from those angles.
8. Remember, that one of your first questions to ask your client is whether or not they used a credit repair firm or disputed items on their credit report within the last year. This is important for the sake of consistency. If a dispute is different than previous ones, it will stagnate the credit repair investigation; meaning that the CB will usually will not verify those disputed items again.
9. Remember to send letters to the credit bureau as if the client is sending the letter. Do not put your information on letters.
10. Never DISPUTE an item on a credit report if is NOT listed on their report. Just because they are on one or two credit reports, if it is NOT on the one you are working on, do NOT dispute it!
11. If you use a third party sites to pull a credit report, you can still a dispute to the credit bureaus based on the content of these reports, the have the same information.
12. When you have your client’s credit report pulled from either annualcreditreport.com or another source, the addresses to send disputes will be listed within.
13. The best way to have tough items deleted is to catch the furnisher in a violation and construct the letter to reflect the you are aware of this violation.
14. Also and this is very important: Credit Bureaus are separate entities. What one is reporting has NOTHING to do with the other. Sending what another credit bureau is reporting is NOT a good strategy. They are competitors and do not care. Make absolute certain that you deal with what they are reporting in their bureau’s file and give your client the ability to take further actions if inaccuracies are not corrected when disputing. Meaning don’t hurt them with frivolous unsubstantiated disputes

Collections/Judgments:

Are they paid or unpaid? Remember if they are unpaid, they can restart the collection process if you challenge them. Therefore you must warn your client of this issue.

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Getting Certified labels online: https://www.certifiedmaillabels.com

If you need to sue a credit bureau:

Marcus Zelman is an excellent choice. 845-367-7146 – http://marcuszelman.com

McCarthy Law – (855)-976-5777 https://www.mccarthylawyer.com/

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Read these next two articles for approaches.

Online Disputing is Bad!!!  https://credithelpdesk.org/kb/online-disputing-is-very-bad/  However, there are some extremely effective methods that some consultants are using and having a lot of success with online disputing.

https://credithelpdesk.org/kb/best-stragety/

https://credithelpdesk.org/kb/trans-union-tu-frivolous-letters/

NOTE: There are usually two ways a lender can report to CRA and it is a good ideal to know what method they use to get a feel for that company’s internal procedures. This always provides their time frame. The two ways are e-Oscar The Metro 2 format. Metro 2 format meets the requirements for the FCBA, FCRA and ECOA. e-Oscar provides an historical perspective and has no mail delays.

Credit Bureaus Addresses:

Experian
P.O. Box 4500
Allen, TX 75013

Experian Phone Numbers:

800-509-8495: Dispute Credit Report Items
888-397-3742: Report Requests & Fraud Help
877-284-7942: Existing Customer Support
888-243-6951: Business Credit Services
972-390-4908: Fax Line

Dispute fax Numbers: 972-390-5790

Equifax Information Services LLC
P.O. Box 740256
Atlanta, GA 30374

Equifax Phone Numbers:

866-349-5186: Dispute Credit Report Items
800-685-1111: Request Free Credit Report
888-766-0008: Place Fraud Alert on Profile
866-493-9788: Existing Customer Support
888-202-4025: Business Solutions
404-885-8078: Fax Number

Dispute fax Numbers: 888-826-0549 – 888-826-0573 – 888-826-0727

TransUnion LLC
Consumer Dispute Center
P.O. Box 2000
Chester, PA 19016

TransUnion Phone Numbers:

800-916-8800: Disputes Items & Status Checks
877-322-8228: Free Annual Credit Report
800-888-4213: Purchase Credit Report
888-909-8872: Place a Security Freeze
800-493-2392: Credit Monitoring Customer Support
866-922-2100: Business Services Assistance
610-546-4771: Fax Machine

Dispute fax Numbers: 610-546-4605 – 610-546-4771

Credit Laws