have 8 tradelines from EFS (which merged with Nelnet), noting loans that were transferred to Nelnet. In all 8 there are a number of lates noted. The dates noted are all during periods when my loans were in deferrment (Full-Time Student, then Unemployed). I disputed these with the 3 CRA's, just got back the dispute results; they claim that EFS verified the information. I'm assuming that my next step should be a CMRR letter to EFS. Correct? What all should be in the letter? I'm assuming that it should: 1) Note rights under FCRA, including: Obligation to report accurate information, and obligation to investigate consumer dispute (§623.(a).8 and §623.(b) ?). 2) List the TL's that are reporting inaccurate information 3) Describe the reasons that the TL's are inaccurate (loans were in deferrment). 4) Demand TL's be delete or accurately updated. Is there anything else that I should be including? Should I add an ITS? Are my FCRA cites correct? thanks!
before doing that i would send a procedure request letter to the CRA and give them the allowed 15 days to reply. once you have that you can include it in your correspondece to EFS stating the CRA says EFS verified it. i'm thinking they never attempted to contact EFS (which EFS may inform you of when they reply to your correspondence).
