Q: Must a furnisher have written policies and procedures?
A: Yes. Each furnisher must establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information relating to consumers that it furnishes to a consumer reporting agency. The policies and procedures must be appropriate to the nature, size, complexity, and scope of each furnisher's activities.
Each furnisher must review its policies and procedures required by this section periodically and update them as necessary to ensure their continued effectiveness.