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1681b vs 1692g


IHateCAs
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A hypothetical with the following facts:

Initial dunning letter received by consumer January 1st, 2006.

Consumer responds with a dispute letter received by CA January 15th, 2006.

No response from CA regarding dispute.

March 1st, CA pulls credit file of consumer.

Violation of 1692g or not? Under the FCRA, they have PP to obtain a report, but is obtaining a consumer file collection activity? I guess it'd have to be since the only reason they can obtain a file is for the collection of an account.

Would that also be a violation of 1681b, since they obtained the report under false pretenses? Because collection activity cannot occur until verification is provided, they were not allowed to use collection as a reason to obtain a file.

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