Milgram v. JPMorgan Chase
The Fair Credit Reporting Act requires furnishers of information to consumer reporting agencies to reasonably investigate disputes consumers make to CRAs regarding the completeness or accuracy of information furnished. The Bureau filed a brief arguing that the statute does not categorically exempt disputes presenting legal questions from the requirement that furnishers conduct such an investigation. Importing this distinction would run counter to the text and purposes of FCRA, would be difficult to implement, and could encourage furnishers to evade their investigation obligation any time they could construe the relevant dispute as a “legal” one. The brief also argues that each time a furnisher fails to reasonably investigate a dispute results in a new statutory violation, with its own statute of limitations.