Under the Fair Credit Reporting Act disputes can be generated based on being incomplete. It could be based on the incompleteness of the credit report, against the credit reporting agency and perhaps even the lender as a furnisher.

Section 1681s-2 of 15 USC refers to a furnisher’s duty to correct and update information and refers to “completeness” of information as a requirement.  So if the lender is making regular reports to CRAs, it has this obligation.  Unfortunately, the remedy provisions seem to limit enforcement to public enforcement, such as by an Attorney General.  But if this is a pattern or practice, there might an AG interested.  See 1681s-2(c) and (d) and 1681s.When disputing, the action against the CRA could be based on section 1681i, requiring CRAs to investigate when a consumer disputes “completeness or accuracy” of information.  Many factors can be covered by “completeness”undefined the report is incomplete.  The CRA has to re-investigate and then correct the report.  If it failed to do so, there could be remedies.  Against the CRA, there are direct remedies, including punitive damages for willful noncompliance.  Even negligent noncompliance carries actual damages and attorney’s fees.  See 1681n and 1681o.When a client has a bankruptcy here is remedy:  Understanding if there is a violation of the discharge injunction. In section 524(j)(2) and (3) of the Bankruptcy code. In these paragraphs says the creditor’s action must be “in the ordinary course of business” and “limited to” seeking or obtaining periodic payments.  If they are obtaining periodic payments from the consumer and refusing to report them correctly in the credit report and do so in the ordinary course of business is a violation of the discharge injunction.  It is a punitive behavior designed to interfere with the fresh start.  Disputing on these causes have resulted in some removals.