What a reinvestigation record has to hold
A description of the procedure used to determine accuracy is a right with a fifteen day clock attached. Here is the record shape that survives.
A results letter arrives and says the item was verified as reported. That is a legitimate outcome and it happens often. What happens next is where most systems stop keeping records, and it is exactly where the statute keeps going.
Two rights that live after the result
FCRA 611(a)(7) gives the consumer the right to request a description of the procedure used to determine the accuracy and completeness of the information, including the business name and address and, where reasonably available, the telephone number of any furnisher contacted. The agency must provide it within fifteen days of the request.
FCRA 611(b) gives the consumer the right to file a statement of the dispute if it is not resolved to their satisfaction. The agency may limit that statement to one hundred words, and may offer help writing a clear summary.
Both are ordinary next steps. Neither is a way of making a verified item disappear, and a system that presents them as one is teaching its users something untrue.
The fifteen day clock is its own clock
The first version we shipped tracked a method of verification request as a note on the parent dispute. It looked tidy and it was wrong. A parent dispute that has already produced a result is closed, so a note on it produced no queue entry, no due date and no escalation. Requests sat.
The request now opens its own clock, with its own rule reference, its own due date and its own queue. It appears in the same expiring window view as everything else. A late response is visible as a late response instead of as a quiet gap in the file.
What a reinvestigation record has to hold
The test we use is simple. Somebody asks about this case in four years, the person who worked it has left, and the question is whether the operator did what it said it did. The record has to answer without anyone reconstructing anything.
- The dispute as sent, with the basis stated, and proof of despatch with a date.
- The date the agency evidenced notice to the furnisher, and the five business day obligation under 611(a)(2) it sits against.
- The written results, attached to the items they answer rather than to the case as a whole.
- The outcome per item: deleted, modified, verified, or withdrawn.
- Any method of verification request, its own fifteen day clock and whatever came back.
- Any consumer statement filed, stored beside the results letter rather than in a separate system.
- Any reinsertion, and the notice to the consumer that 611(a)(5)(C) requires within five business days of it.
Item level, not case level
A dispute usually covers more than one item and a results letter usually answers them differently. Recording one outcome for the case throws away the part that gets asked about, which is why one item was modified and another was verified on the same day by the same letter.
Once outcomes are per item, a partial result stops reading as a full one, and a reinsertion attaches to the item that was reinserted rather than to a case that has moved on.
The thing we will not build
Every few months somebody asks for a feature that automatically resends a dispute on the same item after a verified result, on a schedule. We do not build it. Repetition is not a method of verification, an agency may treat a repeated dispute as frivolous under 611(a)(3), and a system that automates the behaviour is manufacturing the operator's exposure for them.
A new dispute needs a new basis. If there is one, record it and send it. If there is not, the honest next steps are the two the statute already provides.