In a March 2007 deposition, Equifax’s vice president of global consumer services described that bureau’s “reinvestigation” process:
Q: What knowledge do you have as to the mechanics of how a DDC Filipino employee would process an Equifax dispute? [. . .]
A: The electronic image would be displayed on their screen. They would have an ACIS [Automated Consumer Interview System] screen that they would use. They would then look at the electronic image. They would read off the identifying information, enter [. . .] that ID information into the system, access that credit report. At that point, they’d be able to determine if they were looking at the correct file. If they were, they’d go further. They’d read the letter, they gain an understanding of the issues at hand, and they’d look at the credit report to see if the credit report at that time reflects that. If it does, they would send those particular items to the data furnisher or furnishers. They would request that an investigation be started. [. . . .]
Q: Right. But they’re not?they’re not going to handle whatever response the creditor may provide?
A: That’s correct.
Q: Do DDC employees have telephones on their desk?
A: I do not believe so.
Q: As part of their compliance with Equifax’s procedures, do DDC’s employees telephone consumers as part of conducting a reinvestigation?
A: They do not.
Q: Do they telephone creditors, the furnishers, as part of conducting a reinvestigation?
A: They do not.
Q: Do they telephone anybody from outside DDC or Equifax as part of conducting a reinvestigation of a consumer dispute?
A: They do not.
Q: What about emailing any of those non-Equifax, non-DDC people, creditor, consumer, or third
party?
A: They should not be?they do not email them.
Q: And what about fax machines?
A: [. . .] They do not have fax machines either.
Q: Under what circumstances will a DDC employee forward the consumer’s actual dispute letter or documents the consumer provided to the furnisher, the creditor, as part of a reinvestigation?
A: A mechanism does not exist to forward the actual documents.
What makes the process so appalling is that their systems, as described by an Equifax executive, fundamentally cannot comply with the Fair Credit Reporting Act is a travesty of justice for the American consumer.
There is no thought given to the information provided by the consumer. Furthermore, no actual information is considered in the investigation at all! Keep this in mind as you are assisting consumers with their disputes.
