When the credit reporting agency receives a dispute (a formal complaint disputing the validity of information contained in one’s credit file), it must conduct a “reinvestigation.” To do this, the bureau communicates the dispute to the furnisher of the information in question through the use of a consumer dispute verification form (CDV) or “611 notice.” There’s also an automated (electronic) version of the form, known as an ACDV.

The ACDV system was developed by the Big Three, collaborating through the Consumer Data Industry Association (CDIA) to create E-OSCAR (Online Solution for Complete and Accurate Reporting). This computer system takes the place of manual reinvestigation, and consumer disputes are translated into computer codes. This is all done in the name of accuracy, yet, as you will see, the use of this system results in verification, not reinvestigation.

Both CDVS and ACDVs rely on dispute codes to communicate a dispute to a furnisher. When a bureau receives a consumer dispute, someone who would otherwise be flipping hamburgers is tasked with entering it into E-OSCAR. These bureaucrats have quotas that require them to process a certain number of disputes per hour. A former employee of Trans Union testified in a civil trial that she was required to process a dispute every four minutes, or 15 per hour. Since the average consumer dispute involves an average of three items, the actual number that must be entered is 45 per hour.

The dispute is converted to a code using the CDV/ACDV, but the nature of the dispute almost never is, and meanwhile, the actual letter from the consumer often ends up lost in space. (Note that Equifax doesn’t even hire employees in the United States to perform this work. It outsources it, using offices in Jamaica. Trans Union and Experian are also looking to move this area of operations to either the Philippines or India.)