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CHIANG v. MBNA

No. 09-2323.

620 F.3d 30 (2010)

Wen Y. CHIANG, Plaintiff, Appellant, v. MBNA, A Bank of America Company; FIA Card Services, N.A., Defendants, Appellees.

United States Court of Appeals, First Circuit.

Decided September 9, 2010.

Attorney(s) appearing for the Case

Dean Carnahan , with whom Law Offices of Dean Carnahan was on brief, for appellant.

Terry B. Bates , with whom Reed Smith LLP, Bruce D. Berns and Abendroth Berns & Warner LLC, were on brief, for appellees.

Before TORRUELLA, LIPEZ and HOWARD, Circuit Judges.

HOWARD, Circuit Judge.

The Fair Credit Reporting Act imposes certain obligations on entities that furnish credit information to consumer credit reporting agencies (CRAs). See 15 U.S.C. § 1681s-2. One such obligation is to investigate any disputes over the completeness or accuracy of the information furnished and then notify the CRA of any corrections—but only if the CRA, acting as a gatekeeper, has previously notified the furnisher of the consumer...

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