Ingram v. Experian Information Solutions, Inc., No. 21-2430 (3d Cir. 2023)
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Ingram discovered a fraudulent Comcast account in his name for an address where he never lived. Ingram filed a direct dispute with Comcast, which requested several documents, including a notarized FTC fraud and identity theft affidavit. Ingram did not provide that affidavit. Comcast did not decide whether the account was opened fraudulently but referred it to Waypoint for collection. Waypoint then reported the delinquent account to the consumer reporting agency Experian. After the Waypoint account appeared on Ingram’s consumer report, Ingram challenged it in an indirect dispute with Experian, which forwarded notice of the dispute to Waypoint. Waypoint’s employee updated Ingram’s address and confirmed the account name and social security number, but did not further investigate. Waypoint continued to erroneously report that the Comcast account with a balance of $769. Ingram alleges that as a result, his credit score deteriorated and he was denied an apartment rental and loan application. Ingram filed suit under the Fair Credit Reporting and the Fair Debt Collection Practices Acts.
The Third Circuit remanded for evaluation of whether Waypoint’s investigation into Ingram’s indirect dispute was reasonable. Furnishers may find that a direct dispute submitted by a consumer is frivolous, and consumer reporting agencies may find that an indirect dispute submitted by a consumer is frivolous but FCRA provides no such discretion to furnishers that receive an indirect dispute second-hand from a consumer reporting agency.
The court issued a subsequent related opinion or order on October 6, 2023.
The court issued a subsequent related opinion or order on October 6, 2023.
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