Compliance With FCRA’s Requirement To Investigate A Dispute Within 30 Days Does Not Satisfy The FDCPA’s Requirement To Promptly Report A Disputed Debt


In Francisco v. Midland Funding, No. 17 C 6872, 2019 U.S. Dist. LEXIS 20601, at *2 (N.D. Ill. Feb. 8, 2019), the plaintiff sued Midland Funding LLC and Midland Credit Management, Inc. (“MCM”) under the Fair Debt Collection Practices Act (“FDCPA”) for the failure to promptly report the plaintiff’s account as “disputed” to credit bureaus. The FDCPA prohibits debt collectors from “[c]ommunicating or threatening to communicate to any person credit information which is known or which should be known to be false, including the failure to communicate that a disputed debt is disputed.” 15 U.S.C. § 1692e(8) (emphasis added).