Adverse Action

Dispute and Reinvestigation

Dispute and reinvestigation refer to the process that occurs when a consumer questions the accuracy or completeness of information in their background check report. Under the Fair Credit Reporting Act (FCRA), the consumer reporting agency must reinvestigate the disputed information, verify its accuracy, and correct or remove any errors—typically within 30 days.

Compliance note

  • Employers must not take final adverse action while a dispute or reinvestigation is in progress.
  • Consumer reporting agencies are required to complete reinvestigations within 30 days under FCRA Section 611.
  • Consumers have the right to request and receive the results of the reinvestigation, including an updated report if corrections are made.
  • Maintain detailed records of disputes, communications, and timelines to demonstrate compliance with the FCRA and EEOC guidance.

Frequently Asked Questions

Q: What is the difference between a dispute and a reinvestigation?
A: A dispute is when a consumer challenges the accuracy of their background check information. A reinvestigation is the required process the screening agency undertakes to verify and correct that disputed information.
Q: How long does a reinvestigation take under the FCRA?
A: The FCRA generally allows up to 30 days to complete a reinvestigation, or up to 45 days if the consumer provides additional information during the process.
Q: What should employers do if an applicant disputes their background report?
A: Employers should suspend any adverse hiring decision until the reinvestigation is complete and the updated report has been reviewed. Refer to Edify’s Adverse Action Guide for Employers for detailed guidance on compliant procedures.

DISCLAIMER: The information provided in this glossary is for general informational purposes only and should not be construed as legal advice. While we strive for accuracy, EDIFY Background Screening does not guarantee that the definitions or explanations are complete, up to date, or error-free. Employers should always consult with competent legal counsel to ensure compliance with applicable laws and regulations.


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