Guides › The e-OSCAR dispute process for furnishers: ACDV responses, FCRA 623 deadlines and Metro 2

The e-OSCAR dispute process for furnishers: ACDV responses, FCRA 623 deadlines and Metro 2

Consumers: you can't use e-OSCAR yourself. To dispute your credit report, contact Equifax, Experian or TransUnion directly, or the company that reported the item. This page is for lenders and other data furnishers.

Not legal advice. General information, current as of October 17, 2026.

Short answer: e-OSCAR is the online system the credit bureaus and data furnishers use to exchange credit-report disputes. When a consumer disputes a tradeline, the bureau sends the furnisher an ACDV. Under FCRA section 623(b) (15 U.S.C. § 1681s-2(b)), the furnisher must investigate, review everything the bureau sent, and respond within the bureau's reinvestigation period, normally 30 days from the consumer's dispute. Metro 2 is the data format for both the response and ongoing reporting.

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What is e-OSCAR?

e-OSCAR is a web-based, Metro 2-compliant system that furnishers and consumer reporting agencies use to create and answer credit-history disputes. Participants include Equifax, Experian, Innovis and TransUnion, their affiliates, and some independent and mortgage reporting companies (e-OSCAR, "Getting Started"). To register, a furnisher needs an access code from each bureau it reports to.

The e-OSCAR dispute process step by step

Consumer disputes with a bureau online, by mail or by phone.
Bureau creates an ACDV and sends it through e-OSCAR to the furnisher, based on the furnisher's subscriber codes, within 5 business days with all relevant information from the consumer (15 U.S.C. § 1681i(a)(2)).
Furnisher investigates and sends the ACDV back: account verified as reported, changed, or deleted.
Bureau updates the file and notifies the consumer of the results (§ 1681i(a)(6)).
Carbon copies: if the furnisher changes or deletes the account, e-OSCAR sends copies to every other bureau the furnisher reports to.

ACDV vs. AUD

ACDV (Automated Credit Dispute Verification): started by a bureau on behalf of a consumer, answered by the furnisher.
AUD (Automated Universal Dataform): started by the furnisher to correct a record outside the monthly reporting cycle. e-OSCAR says the system may not be used to add or create a record on a consumer's file or to substitute for regular in-cycle reporting (e-OSCAR, "Getting Started").

How to respond to an ACDV

Read the dispute code and the consumer's narrative, and open every attached document.
Check source records (application, payment history, charge-off date, ownership or chain of title), not only your current system screen.
Confirm each Metro 2 field in question: balance, status, date of first delinquency, payment rating, ownership.
Respond with corrected data, or delete the item if you can't verify it (§ 1681s-2(b)(1)(E)).
Keep a record of what you reviewed and why you decided as you did.

Courts require a reasonable investigation, not just matching codes against your system (Johnson v. MBNA America Bank, N.A., 357 F.3d 426 (4th Cir. 2004)).

FCRA 623 dispute response times

Step	Deadline	Cite
Bureau notifies furnisher	Within 5 business days of receiving the dispute	15 U.S.C. § 1681i(a)(2)
Bureau reinvestigation	30 days from the dispute	§ 1681i(a)(1)(A)
Extension	Up to 15 more days if the consumer sends relevant information during the 30 days	§ 1681i(a)(1)(B)
Furnisher investigation (FCRA 623(b))	Must be finished within the bureau's period	§ 1681s-2(b)(2)
Direct dispute to furnisher (FCRA 623(a)(8))	Generally 30 days	§ 1681s-2(a)(8)(E); 12 C.F.R. § 1022.43(e)

Because the bureau uses part of the 30 days before the ACDV arrives, the furnisher's working window is shorter. If the furnisher does not respond in time, the bureau generally must delete or modify information it cannot verify (15 U.S.C. § 1681i(a)(5)(A)).

Consumers can sue furnishers who violate section 623(b) for willful or negligent noncompliance (§§ 1681n, 1681o). There is no private right of action for the separate accuracy duties in section 623(a) (§ 1681s-2(c)).

Metro 2 reporting for disputed accounts

Metro 2 is the standard credit-reporting format, maintained by the Consumer Data Industry Association (CDIA). While a dispute is open, and after it is resolved, furnishers report its status in the Compliance Condition Code (CCC) field (the duty to flag a disputed account comes from 15 U.S.C. § 1681s-2(a)(3)). FCRA section 623(a)(3) requires a furnisher to tell the bureaus when an account is disputed by the consumer. Make sure the CCC and key dates (including date of first delinquency) are consistent across all bureaus.

Direct disputes under FCRA 623(a)(8)

Consumers can also dispute directly with you. Regulation V (12 C.F.R. § 1022.43) sets out which direct disputes you must investigate. Generally you must finish within 30 days. You may treat a dispute as frivolous if it lacks enough information, but you must notify the consumer within 5 business days (§ 1022.43(f)). These disputes don't come through e-OSCAR, so you need a separate intake process.

CFPB guidance status (2025)

On May 12, 2025, the CFPB withdrew 67 guidance documents (90 Fed. Reg. 20084), including Bulletins 2013-09 and 2014-01 and Circular 2022-07 on reasonable investigation of consumer reporting disputes. The Bureau called the withdrawal 'not necessarily final'; as of October 17, 2026, none of these furnisher items (including CFPB Circular 2022-07) had been reinstated. The FCRA and Regulation V are unchanged, and consumers can still sue (90 Fed. Reg. 20084).

Common ACDV response mistakes

answering by matching codes without opening the attachments;
missing the deadline (if the furnisher does not respond in time, the bureau generally must delete or modify information it cannot verify, 15 U.S.C. § 1681i(a)(5)(A));
inconsistent date of first delinquency or charge-off date across bureaus;
continuing to report an account after it was sold or paid;
no written procedures or quality checks.

Disputes after you sell a portfolio

When charged-off accounts are sold, the seller typically updates its tradelines to show the account was sold or transferred with a zero balance. The buyer, if it reports, becomes the furnisher for its own tradeline and answers future disputes about it. Generally, the buyer is responsible for its own collection and reporting conduct after the sale, and you remain responsible for conduct before the sale. The purchase agreement should say who handles disputes during the transition and how the buyer gets the documents it needs.

For lenders with small back-office teams, ongoing ACDV work on old charge-offs is a real cost, and one reason to consider a sale. SellChargeOffs is a seller-side service: we introduce you to debt buyers and help compare bids, and we do not buy debt. Request a free valuation or estimate a price range. A valuation is an estimated range based on market data, not a bid or offer.

What else do sellers ask?

How long does a furnisher have to respond to an ACDV?

It must finish within the bureau's reinvestigation period: 30 days from the consumer's dispute, or up to 45 if extended, minus the time the bureau has already used (15 U.S.C. §§ 1681i(a)(1), 1681s-2(b)(2)).

What is FCRA section 623?

It's the furnisher section of the FCRA, codified at 15 U.S.C. § 1681s-2. Subsection (a) covers accuracy and direct disputes; subsection (b) covers disputes sent through a bureau.

What is the difference between an ACDV and an AUD?

A bureau sends an ACDV to a furnisher about a consumer's dispute. A furnisher sends an AUD to correct a record outside the normal reporting cycle.

How is a disputed account reported in Metro 2?

Through the Compliance Condition Code, which shows that the consumer disputes the account and, later, how the dispute was resolved.

Can consumers use e-OSCAR?

No. Consumers dispute through the bureaus or directly with the furnisher.

Where should you go next?

General information only, not legal advice. Laws and FCC/CFPB rules change; verify with counsel. SellChargeOffs is a seller-side service and does not buy or collect debt.