CFPB Circular 2022-07 Reasonable Investigation of Consumer Reporting Disputes (Congressional Review)

Current understanding

A joint resolution has been introduced under the Congressional Review Act (chapter 8 of title 5) to disapprove the CFPB’s rule withdrawing Consumer Financial Protection Circular 2022-07, which had articulated that consumer reporting agencies and furnishers must conduct reasonable investigations of disputed information under the FCRA. If enacted, the disapproval would nullify the withdrawal, effectively restoring the circular’s guidance on dispute-investigation obligations for entities handling consumer credit data. Status: introduced.

Evidence log

• 2026-05-13 — A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to the withdrawal of the rule relating to “Fair Credit Reporting; Background Screening”.: cross-connection with sjres133-cfpb-background-screening-rule-withdrawal: Both concern CFPB oversight of consumer reporting agency practices under the FCRA. (novelty: 2)
• 2026-07-09 — To amend the Fair Credit Reporting Act to restore the impaired credit of victims of predatory activities and unfair consumer reporting practices, to expand access to tools to protect vulnerable consumers from identity theft, fraud, or a related crime, and protect victims from further harm, and for other purposes.: cross-connection with identity-theft-consumer-protection-tools: Both address FCRA-governed consumer reporting accuracy and dispute handling; HR9639’s credit-restoration provisions intersect with CFPB guidance on reasonable investigation of disputes. (novelty: 2)
• 2026-05-11 — Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to the withdrawal of the rule relating to “Consumer Financial Protection Circular 2022-07: Reasonable Investigation of Consumer Reporting Disputes”.: cross-connection with cfpb-circular-2022-04-data-protection: Parallel CRA disapproval resolutions challenging CFPB withdrawals of 2022-era circulars on consumer financial data — one on data security (2022-04), the other on dispute-investigation standards (2022-07). (novelty: 2)

Open questions

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