CFPB Resumes Enforcement of Credit Reporting Dispute Deadlines

The Consumer Financial Protection Bureau has resumed enforcing FCRA requirements for credit report disputes, rescinding the leeway it gave to the credit reporting bureaus during the COVID-19 pandemic.

By , Attorney · University of Denver Sturm College of Law

Your credit report is a record of all open credit accounts you have, as well as your payment history with each of them. The three national credit reporting agencies—Equifax, Experian, and TransUnion—keep these records, and federal law gives you the right, under the Fair Credit Reporting Act (FCRA), to dispute errors and inaccuracies in your reports. Federal law also requires the agencies to respond to disputes within specific time limits.

Generally, the FCRA requires that credit reporting agencies and furnishers, like creditors, investigate disputes within 30 days of receipt of the consumer's dispute. The agency can extend the 30-day period to 45 days if the consumer provides additional information relevant to the investigation during the 30 days.

But the COVID-19 pandemic had a profound effect on how quickly agencies and furnishers could deal with disputes.

What Happened to Credit Reporting Disputes During the COVID Pandemic?

Like other businesses, credit reporting agencies and furnishers of credit information faced significant operational disruptions during the COVID-19 national emergency.

So, in April 2020, in the early stage of the pandemic, the Consumer Financial Protection Bureau (CFPB), which usually enforces the FCRA, issued a statement saying it would give the credit reporting agencies and furnishers flexibility in meeting dispute investigation deadlines. The CFPB said it wouldn't cite in an examination or bring an enforcement action for exceeding the deadlines to investigate such disputes, so long as they made good-faith efforts during the pandemic to do so as quickly as possible.

Now, however, the CFPB has changed its tune and announced it will now enforce the FCRA and has rescinded the flexibilities given to the credit agencies and furnishers during the COVID crisis.

Credit Protections Under the CARES Act

Under the federal Coronavirus Aid, Relief, and Economic Security (CARES) Act, if you made an agreement with a creditor or lender for payment relief because you were affected by the COVID-19 pandemic, that creditor or lender had to report your account as current if you weren't already delinquent.

But you must have made the arrangement with the creditor or lender before falling behind on the debt to avoid adverse reporting, and you had to stick to the terms of the deal. You couldn't just stop making your payments, delay making payments, or pay less than the minimum amount without getting permission. If you were already delinquent at the time of the agreement, the creditor or lender could keep reporting the past-due status unless you brought the account up to date.

Some people, however, took a hit to their credit during the pandemic in violation of the CARES Act. The CFPB's Consumer Response Annual Report says that credit report inaccuracies more than doubled during that time. So, it's a good idea to review your credit reports to make sure your credit wasn't wrongfully damaged during the time the CARES Act protections were in effect.

The credit reporting protections under the CARES Act expired 120 days after the national emergency concerning COVID–19 ended on May 11, 2023.

What You Can Do to Review and Protect Your Credit

Get copies of your credit reports and verify that the creditor or lender reported your account the right way while the CARES Act was in place. You can get free credit reports at

If, after reviewing the reports, you find that a creditor or lender improperly reported your debt as delinquent, you should file a dispute with the agency that made the report. The agency must respond by the deadlines imposed by the FCRA.

If your dispute doesn't resolve the issue, you can add an explanatory statement to the report. Once you file a statement about the dispute with a credit reporting agency, the agency must include it (or a summary) in any report that includes the disputed information. If the agency helps you write the explanation, it may limit your statement to 100 words. Otherwise, there isn't a specific word limit. But it's a good idea to keep the statement very brief. That way, the agency is more likely to use your unedited account.

You might also consider initiating a lawsuit or filing a complaint with your state Attorney General's office and the CFPB.