What is the FCRA?
The Fair Credit Reporting Act is the federal statute that governs consumer reports. It is codified at 15 U.S.C. §§1681–1681x (15 U.S.C. §§1681–1681x). A consumer report is the file a consumer reporting agency keeps about a person and that users rely on for credit, insurance, employment, and similar decisions. Collectors and creditors meet the Act when they furnish account data into that system, and when they use a report.
It is written for furnishers and collection teams. It is not legal advice.
Consumer reporting agencies, furnishers, and users
Three roles show up in almost every FCRA workflow. A consumer reporting agency assembles and sells the consumer report. A data furnisher is the creditor, collector, or debt owner that supplies account information to that agency. A user obtains the consumer report for a purpose the statute allows. The same company can be a furnisher on accounts it reports and a user when it pulls a file. The duties below attach to the furnisher role.
FCRA vs FDCPA
The two statutes answer different questions. The FCRA covers consumer reports (15 U.S.C. §§1681–1681x). The FDCPA covers the conduct of third-party debt collectors (FDCPA text; 15 U.S.C. §1692a). A collector can owe duties under both on the same account: one set when it speaks to the consumer, and another when it reports the account. The practical guide to the FDCPA and Regulation F is the FDCPA guide.
| Question | FCRA | FDCPA |
|---|---|---|
| What it covers | Consumer reports and the companies that furnish or use them (15 U.S.C. §§1681–1681x). | Conduct of third-party debt collectors (FDCPA text; 15 U.S.C. §1692a). |
| Core furnisher or collector duty on this page | Accuracy, written policies, dispute investigation, and the date of delinquency (15 U.S.C. §1681s-2; 12 CFR 1022.42; 12 CFR 1022.43). | Who is a debt collector, call limits, the validation notice, and time-barred debt. See the FDCPA guide. |
| Where the text lives | 15 U.S.C. §§1681–1681x and Regulation V, 12 CFR part 1022. | 15 U.S.C. §1692 et seq. and Regulation F, 12 CFR part 1006. |
Furnisher duties under §623 (15 U.S.C. §1681s-2)
Section 623 is the furnisher section. For a collector or creditor that reports accounts, four duties carry the day-to-day work: do not furnish information you know is inaccurate, keep written accuracy and integrity policies, investigate disputes, and report the date of delinquency on collection and charge-off accounts (15 U.S.C. §1681s-2; 12 CFR 1022.42; 12 CFR 1022.43).
Accuracy: no known-inaccurate data
A furnisher must not furnish information to a consumer reporting agency that it knows or has reasonable cause to believe is inaccurate (15 U.S.C. §1681s-2, §1681s-2(a)(1)(A)). That is the accuracy duty in plain words. If the furnisher knows the balance, status, or date is wrong, it does not send that item. The statute, not a bureau score, is the standard.
Written policies and procedures
Furnishers must establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information they furnish (12 CFR 1022.42, 12 CFR 1022.42(a)). A verbal habit on the collection floor is not the policy the regulation describes. The written policy is what a reviewer can read.
Date of delinquency within 90 days
When a furnisher reports a collection account or a charge-off, it must report the date of delinquency, and it must do so within 90 days of furnishing that item (15 U.S.C. §1681s-2, §1681s-2(a)(5)). That date is the date of first delinquency the seven-year clock uses. A charge-off does not create a new delinquency date. The date that matters is the delinquency that led to the collection or charge-off.
How long collections stay on a credit report: the 7-year rule
The seven-year rule is a reporting limit in the FCRA, not a promise that every unpaid bill disappears on a calendar the collector chooses.
Accounts placed for collection or charged to profit and loss
Consumer reports may not include accounts placed for collection or charged to profit and loss that antedate the report by more than seven years (15 U.S.C. §1681c, §1681c(a)(4)). The period runs from the delinquency, not from the date a later collector acquired the account. Reporting an older collection as if it were new is the problem the next section names.
Why re-aging the date breaks the rule
Re-aging means changing the date of first delinquency so the item looks younger than §1681c(a)(4) allows. The furnisher duty in §1681s-2(a)(5) exists so the bureau receives the real delinquency date (15 U.S.C. §1681s-2). Moving that date to the purchase date, the placement date, or the last payment a later agency posted is not a new delinquency. The operating note on that failure mode is the re-aging discussion.
FCRA disputes: indirect (via the bureau) and direct
An FCRA dispute is a consumer challenge to the accuracy of reported data. It can travel through a bureau or go straight to the furnisher. Both paths require an investigation. Neither path is optional once it is a dispute the rule covers.
Indirect disputes through e-OSCAR and Metro 2
In the indirect path, the consumer files with the consumer reporting agency, and the agency routes the dispute to the furnisher. The CFPB's December 2012 paper on the U.S. credit reporting system describes that routing, including the e-OSCAR system and the Metro 2 format furnishers use (CFPB credit-reporting paper (December 2012)). The dispute codes and the furnisher response are the subject of the e-OSCAR and Metro 2 note.
Direct disputes: reasonable investigation
A consumer may also dispute directly with the furnisher. The furnisher must conduct a reasonable investigation of a direct dispute (12 CFR 1022.43, 12 CFR 1022.43). Reasonable means the furnisher looks at the information the consumer sent and the records the furnisher has. A form letter that does not review the account is not the investigation the regulation names.
Permissible purpose and adverse action notices
Permissible purpose and the adverse-action notice are user-side rules in the statute (15 U.S.C. §§1681–1681x). This page does not restate either rule. Read them in the FTC text.
FCRA compliance checklist for agencies and debt sellers
Each line below is a furnisher control tied to one cited duty. It is a reading list for an operating team, not a finding that any particular agency is in or out of compliance.
- Do not furnish an item you know, or have reasonable cause to believe, is inaccurate (15 U.S.C. §1681s-2, §1681s-2(a)(1)(A)).
- Keep and follow reasonable written policies and procedures on the accuracy and integrity of furnished information (12 CFR 1022.42, 12 CFR 1022.42(a)).
- When you furnish a collection or charge-off, report the date of delinquency within 90 days (15 U.S.C. §1681s-2, §1681s-2(a)(5)).
- Do not treat a later placement or sale as a new delinquency date. Accounts placed for collection or charged off that antedate the report by more than seven years are excluded (15 U.S.C. §1681c, §1681c(a)(4)).
- Investigate indirect disputes that arrive through the bureau, using the e-OSCAR and Metro 2 path the CFPB described (CFPB credit-reporting paper (December 2012)).
- Conduct a reasonable investigation of a direct dispute (12 CFR 1022.43, 12 CFR 1022.43).
Related guides on this site: FDCPA and Regulation F, TCPA for collection calls, the ARM industry, and the compliance and consumer rights hub.
FAQ
What does FCRA stand for?
Fair Credit Reporting Act, codified at 15 U.S.C. §§1681–1681x (15 U.S.C. §§1681–1681x).
Does the FCRA apply to debt collectors?
When a collector reports accounts to a consumer reporting agency it is a furnisher, with duties under 15 U.S.C. §1681s-2 (15 U.S.C. §1681s-2) and 12 CFR 1022.42–1022.43 (12 CFR 1022.42; 12 CFR 1022.43).
How long can a collection account stay on a credit report?
Accounts placed for collection or charged off that antedate the report by more than seven years are excluded (15 U.S.C. §1681c, §1681c(a)(4)).
What is an FCRA dispute?
A consumer challenge to the accuracy of reported data, either through a bureau (routed to furnishers via e-OSCAR, as the CFPB described in December 2012, CFPB credit-reporting paper (December 2012)) or directly to the furnisher, which must reasonably investigate (12 CFR 1022.43).
What is the difference between the FCRA and the FDCPA?
The FCRA covers consumer reports (15 U.S.C. §§1681–1681x). The FDCPA covers conduct of third-party debt collectors (FDCPA text; 15 U.S.C. §1692a).
Sources
Accessed October 26, 2026. Statute text is the FTC compilation revised March 2026, the USCODE-2023 govinfo pages, and eCFR Title 12 as of October 22, 2026.
- FTC, Fair Credit Reporting Act, 15 U.S.C. §§1681–1681x.
- 15 U.S.C. §1681c (govinfo, USCODE-2023).
- 15 U.S.C. §1681s-2 (govinfo, USCODE-2023).
- 12 CFR 1022.42.
- 12 CFR 1022.43.
- CFPB, Key Dimensions and Processes in the U.S. Credit Reporting System (December 2012).
- FTC, Fair Debt Collection Practices Act text.
- 15 U.S.C. §1692a (govinfo, USCODE-2023).
Related guides
TCPA, FDCPA, credit cycle, calculating receivables, write-off entries, the ARM industry.
Jeffery Hartman introduces qualified buyers and sellers of charged-off and non-performing debt portfolios. He does not buy debt, act as a broker, or negotiate for either side.