Primer
The federal-law mechanics this app implements. Read once, reference forever.
This is a self-help primer, not legal advice.
Consumer-protection statutes are jurisdiction-specific and the application of them turns on facts. If you're considering litigation, intent-to-sue language, or anything materially adversarial, consult a licensed attorney in your state. Many of them take FCRA cases on contingency under §1681n(a)(3).
The three statutes
Everything this app does sits on top of these. None of them are paywalled — you can read each on Cornell's LII for free.
Governs the credit reporting agencies (Equifax, Experian, TransUnion) and the furnishers (creditors, debt collectors, etc.) that report to them. Gives you the right to dispute inaccurate info, demand investigation results, and collect statutory damages for willful noncompliance.
Key sections
- §1681cWhat the bureaus may NOT report (obsolete items, expunged records, etc.)
- §1681e(b)Bureaus must follow reasonable procedures to assure maximum possible accuracy
- §1681gYour right to disclosure of your full file (§609 letters)
- §1681iThe dispute / reinvestigation process (the §611 letter)
- §1681nCivil liability for willful noncompliance — actual + statutory $100–$1,000 + punitive
- §1681oCivil liability for negligent noncompliance — actual + costs + attorney fees
- §1681s-2(a)(8)Direct dispute to a furnisher — the §623 letter
Governs how third-party debt collectors (NOT original creditors) can interact with you. Gives you the right to demand validation of any debt and to dispute collector misconduct.
Key sections
- §1692eFalse or misleading representations of the character / amount / legal status of a debt
- §1692gValidation of debts — the §809 letter. Within 30 days of first contact, you can demand the collector substantiate the debt before continuing collection.
- §1692kCivil liability — actual + up to $1,000 statutory + costs + fees
Not a statute — it's the technical format furnishers use to transmit data to the bureaus. Errors in Metro 2 fields (missing credit limit on revolving, balance > limit, payment status that contradicts other fields) become §1681e(b) accuracy violations.
Key sections
- Credit limit fieldRequired on every revolving account. If missing, bureaus default to high_balance and inflate utilization.
- Payment history grid24-month code per month. Inconsistencies between this and the current paymentStatus are disputable.
- Date of First DelinquencyThe single most contested field. Drives the §605 7-year clock. See section below.
The clocks (FCRA §605)
A bureau may not report most adverse items past these limits. The clock starts at very specific moments — getting the start date wrong is the most common violation.
7 years — most adverse items
From Date of First Delinquency (the date the account first went 30+ days past due AND was not subsequently brought current). Applies to charge-offs, collections, late payments, and most other negative items under §1681c(a)(4)–(5).
10 years — Chapter 7 bankruptcy
From the date of entry of the order for relief or the date of adjudication, per §1681c(a)(1). Chapter 13 typically reports for 7 years voluntarily under CDIA policy, but the legal ceiling is 10 for any chapter.
Re-aging — when a furnisher moves the DoFD forward to extend the clock — is a §1681s-2(a)(5)(A) violation. The cross-bureau view at /tradelines compares DoFD across all three bureaus and flags inconsistencies.
The dispute workflow
Each step has a specific statute, recipient, and response window. Send certified mail, return-receipt-requested. Always.
Your first letter for any item the rules engine flagged. Specific, statute-cited, not 'dispute everything.'
fcra_611_initialBureau came back 'verified' with no detail. Demand the furnisher's name + address + actual investigation procedure. Most e-OSCAR-only verifications can't survive this.
mov_followupRequired precursor to a §623(b) private right of action. Goes to the original creditor / current servicer, AFTER the bureau dispute on the same item.
fcra_623_furnisher_directAnytime a collector reports a debt. Demands they substantiate the debt before continuing collection or reporting. Most powerful within 30 days of first contact.
fdcpa_809_validationBureau / furnisher hasn't responded substantively after the above. The CFPB forwards your complaint to the company; their response goes into a public database.
cfpb_complaintState AGs have concurrent FCRA enforcement under §1681s(c)(1)(B) plus state UDAP authority. CA, NY, MA AGs are particularly active.
state_ag_complaintLast step before filing. Cites statutory damages of $100–$1,000 per willful violation + actual + punitive + fees. DRAFT ONLY — review with counsel before sending.
intent_to_sueWhat good disputes look like
The difference between a successful dispute and a §1681i(a)(3) frivolous-or-irrelevant rejection.
Common myths and traps
The credit-repair internet is full of bad advice. Here's what doesn't work.
Myth: “Send 30+ disputes at once and the bureau will delete out of overwhelm”
Reality — The bureau categorizes mass disputes as frivolous under §1681i(a)(3) and refuses to investigate. You may also damage credibility for legitimate items in the same batch.
Myth: “609 letters are a magic deletion strategy”
Reality — §609 is the file-disclosure statute, not a deletion mechanism. Used correctly (combined with §611), it forces the bureau to produce documentation of the verification — which is often missing. On its own, it doesn't compel deletion.
Myth: “Goodwill letters always work if you mention hardship”
Reality — Goodwill is at the creditor's sole discretion. Success rate ~10–25% in our data. Best targets: isolated 30/60-day late marks on accounts otherwise in good standing, with a brief plausible reason.
Myth: “Pay the collection and they'll remove it”
Reality — Most collectors will NOT delete after payment unless you have a written pay-for-delete agreement BEFORE you pay. Without one, they'll mark it 'paid collection' — still negative. See the pay_for_delete template.
Myth: “My state's SOL means the debt is gone”
Reality — The statute of limitations limits the collector's ability to sue, not their ability to report. The §605 7-year clock is what controls reporting. The two are different.
Identity-theft track
If accounts on your file are not yours, the path is different — and stronger.
File an FTC ID-theft affidavit at identitytheft.gov/Affidavit (free, takes ~15 minutes). File a police report. Upload both to /settings.
With an affidavit on file, FCRA §605B (15 U.S.C. § 1681c-2) requires the CRA to block the disputed information within 4 business days of receiving the affidavit + police report. This is substantially stronger than a §611 dispute — the burden flips to the furnisher to prove the account IS yours.
Without the affidavit on file, this app's guardrails refuse to produce letters that contain "not mine" / "identity theft" language — see NOT_MINE_WITHOUT_FRAUD_FLAG.
Building credit (alternatives to dispute)
Disputes remove what's wrong. These add what's right. The whole credit-improvement playbook isn't just defense — most of the fastest wins are constructive.
▶Details + how-to
Best target: a family member with a card that's 10+ years old, low utilization (under 10%), and never late. You don't need access to the physical card — they keep it, they keep using it, you just inherit the credit history.
Timing: shows up on your report within 1–2 statement cycles (30–60 days). FICO 8 counts it; FICO 9 weights it less but still counts. Some scoring models ignore it entirely.
Risk to you: if the primary cardholder misses payments, the lateness can appear on your report too — though many issuers (Chase, Bank of America, Citi) don't report AUs to the bureaus when accounts go delinquent. Pick a primary who is reliably on-time.
Risk to them: none, really. Adding an AU doesn't affect their score. The AU can't request credit-limit increases, can't make changes, and the primary remains solely liable.
When to remove yourself: if you ever apply for a mortgage and a lender questions it, or if the primary runs up the card and tanks the utilization. The bureaus remove the tradeline from your report in one cycle.
▶Details + how-to
Recommended issuers (no annual fee, graduate to unsecured after 6–12 months of on-time payments): Discover it Secured, Capital One Platinum Secured, Chime Credit Builder (no deposit, but tied to a checking account balance).
Avoid: First Premier, Credit One, Total Visa — these charge $75–$95 annual fees + $9.95/month "maintenance" fees. They prey on subprime credit.
Use it correctly: charge $5–$20/month, pay in full before the statement closes. Goal is reported utilization <9%. After 6 months you'll see real score movement.
▶Details + how-to
Vendors: Self.inc, MoneyLion, Kikoff, your local credit union. Typical terms: $25/mo for 12–24 months, ~10–15% APR.
How it works: the lender opens a CD or savings account in your name. You make monthly payments that fund it. After the term, you get the funds (minus interest). The reported payment history during those 12–24 months is the credit-building product.
Why it works: credit mix is ~10% of your FICO. If your file is all revolving cards, adding an installment account literally moves the "mix" factor up. Plus you get 12–24 months of fresh on-time payment history.
Tradeoff: you're paying interest to report payments. Math is roughly $200–$400 in interest over 24 months for a real score bump. Worth it if you have a thin file.
▶Details + how-to
When a card closes, two things happen:
- Its limit drops out of your utilization calculation — remaining cards now look more maxed out.
- After ~10 years, the closed account drops off your file entirely, taking its age contribution with it.
What to do instead: charge a small recurring expense (Netflix, a phone bill) to the old card, set autopay. Card stays open, no annual fee triggers, and you preserve the credit age.
Exception: if it has an annual fee you can't justify, call the issuer and ask to product-change to a no-fee card. The age + history transfers; only the fee disappears.
▶Details + how-to
Scoring models pull from your bureau file when a lender requests a credit pull. Bureau files normally update monthly when furnishers send their data. Rapid rescore is a paid service (only mortgage brokers have access) that forces a bureau to re-pull from the furnisher mid-cycle.
When it matters: you're applying for a mortgage and your rate hinges on a specific score threshold. You pay down a balance, but your bureau file won't reflect it for 2–4 weeks. Rapid rescore gets it reflected in 3–7 days.
Doesn't work for: disputes (only payment-balance updates), regular credit applications (only mortgages), or non-furnisher updates. It accelerates the reporting of data the furnisher has — it doesn't change anything on the report.
If you go to court
When self-help is exhausted and you have provable damages.
FCRA cases are usually filed in federal district court under 28 U.S.C. § 1331 (federal-question jurisdiction). Smaller cases (especially against single furnishers) sometimes go to state small-claims, but the §1681n statutory-damages provisions and attorney's-fees recovery favor federal court for cases with real damages.
Damages you can claim: actual damages (denied credit, increased interest rates, time spent disputing, emotional distress), statutory damages of $100–$1,000 per willful violation, punitive damages, costs, and reasonable attorney's fees.
Many FCRA attorneys take cases on contingency. Look for firms with FCRA litigation as a substantial practice area: Francis Mailman Soumilas, Lemberg Law, Stein Saks, NCLC members. They get paid from §1681n(a)(3) fee-shifting; you typically owe nothing out-of-pocket if they take the case.
The intent_to_sue template here is a self-help draft. It is NOT a substitute for retaining counsel before filing suit. Use it to communicate seriousness and preserve your rights, then talk to a lawyer.
Further reading
- CFPB consumer guide to credit reports
- FTC FCRA reference
- National Consumer Law Center — practitioner-grade reference materials
- John Ulzheimer's podcast / writing — practical mechanics of credit reporting from a former FICO insider