CFPB Files Lawsuit Against Experian for “Sham” Investigation Into Credit Report Errors

By The Kim Law Firm, LLC

On January 7th, 2025, the Consumer Financial Protection Bureau (CFPB) announced a lawsuit against Experian. The CFPB alleges that the credit reporting agency failed to properly investigate consumer disputes. I represent consumers against the credit bureaus in exactly this kind of failure. This article covers what the CFPB alleged, where the case stands now, and what it means for your own dispute; the credit reporting agencies page covers how a dispute against a bureau works.

What is Experian?

Also referred to as a credit bureau, a credit reporting agency is a private company that collects, maintains, and sells information related to the credit history of individual consumers. Experian is one of the nation’s three major credit reporting agencies; the other two are Equifax and TransUnion. Notably, these companies must comply with federal and state law. 

The allegations: Experian failed to conduct proper investigations

The Consumer Financial Protection Bureau has filed a consumer protection lawsuit against Experian. The federal agency alleges that the credit bureau failed to properly investigate consumer disputes. As a direct consequence of the “sham” investigations alleged by the CFPB many consumers had incorrect adverse information on their credit reports. The CFPB alleges violations of the federal Fair Credit Reporting Act (FCRA). Among other things, the agency accuses Experian of: 

• Systematically conducting inadequate investigations into consumer complaints; 
• Frequently disregarding key details provided by consumers; and 
• Blindly accepting responses from furnishers (creditors, debt collectors, etc). 

The lawsuit also contends Experian will often improperly reinsert previously deleted inaccurate information into consumer credit reports. As a result, there can be considerable confusion, and the affected consumers can be directly harmed as incorrect adverse information can undermine a person’s ability to access credit, get a fair interest rate, obtain housing, and even get a job. As part of the lawsuit, the CFPB is seeking to stop the violations, require Experian to ensure compliance with the FCRA and recover financial compensation for affected consumers. 

Where the case stands (September 2026)

The case is still being litigated in the United States District Court for the Central District of California, No. 8:25-cv-00024, and the CFPB’s enforcement page lists it as pending. The docket so far: the complaint was filed on 7 January 2025. Experian moved to dismiss, and on 5 May 2025 the court ruled on that motion, allowing the claims about Experian’s ongoing dispute practices to proceed. The CFPB filed a first amended complaint on 6 June 2025; on 6 August 2025 the court dismissed, with leave to amend, the counts covering discrete violations between 2018 and 2021 as untimely. The CFPB filed a second amended complaint on 22 August 2025, and on 22 October 2025 the court denied Experian’s motion to dismiss and strike those counts, finding that the Bureau had adequately alleged that the limitations period was tolled. The core reinvestigation claims have never been dismissed; the case is in the pretrial stage. I will update this page when it moves. An earlier episode of the same pattern — a commitment to fix dispute handling that was not kept — is in Experian forgot to do what it said it would do (2020).

The FCRA protects consumers from credit report errors

Credit reporting agencies must comply with the FCRA. The law helps to protect consumers against harm caused by credit report errors. It requires credit reporting agencies like Experian to ensure the accuracy of consumer information and to properly investigate disputes. Consumers have the right to challenge incorrect data and receive a fair review. The FCRA also prevents previously removed inaccurate information from being reinserted without proper verification. Notably, consumers can file an FCRA lawsuit on their own and do not have to wait for the CFPB or any other government entity to take action.

What the case means for your own dispute

You do not have to wait for the CFPB. The Act gives a consumer a private claim against a bureau that fails to conduct a reasonable reinvestigation of a dispute, or that reinserts a deleted item without certifying it, and the conduct alleged in this case — a dispute reduced to a code, the furnisher’s answer accepted without review, a deleted item back on the file the next month — is the same conduct those claims are built on. What you need is the record: the report before the dispute, the written dispute and the documents you attached, the delivery receipt, the bureau’s result, and the report afterward. If the bureau “verified” an entry your documents contradicted, ask it in writing for a description of the reinvestigation it performed; the Act requires the bureau to provide one, and the answer is usually the evidence. A claim under the Act must be filed within two years of the day you discovered the violation, and never more than five years after it happened. I review the file at no cost and bring these cases on contingency: you pay nothing unless we win.

Sources: Consumer Financial Protection Bureau, CFPB Sues Experian for Sham Investigations of Credit Report Errors (press release, 7 January 2025) and the Bureau’s enforcement page for Experian Information Solutions, Inc. (status “Pending Litigation”); CFPB v. Experian Information Solutions, Inc., No. 8:25-cv-00024 (C.D. Cal.), orders of 5 May 2025, 6 August 2025 and 22 October 2025; 15 U.S.C. §§ 1681i, 1681n, 1681o and 1681p (United States Code).

Admitted in Pennsylvania and New Jersey; available to appear pro hac vice in other federal courts.

The agencies subject to the same investigation duty

An enforcement action against one bureau is worth reading as a description of an industry practice rather than a single company’s failure. The conduct at issue, forwarding a dispute as a two-digit code, accepting whatever the furnisher sends back, and calling the result an investigation, is available to every consumer reporting agency operating at volume. The nationwide bureaus are the largest, but the same reasonable-procedures standard applies to the specialty agencies that report checking account history, rental applications and alternative lending data.

• Experian — one of the three nationwide credit reporting agencies.
• Equifax — subject to the identical reinvestigation obligations.
• TransUnion — the third nationwide bureau maintaining consumer files.
• ChexSystems — a specialty agency reporting deposit account history.
• Early Warning Services — a bank-owned agency reporting account and fraud data.
• Innovis — a smaller nationwide agency maintaining its own consumer files.

Dispute in writing and describe the error factually, attaching the documents that establish it, because a paper record is what distinguishes a dispute the agency can process mechanically from one it has to actually examine. Ask what the agency did in response rather than accepting a result code, and request the reinvestigation description the statute entitles you to. When an agency verifies an entry your documents plainly contradict, the failure is in the procedure, and that is precisely what enforcement actions in this area have targeted.

If Experian has already investigated your dispute and verified an error anyway, the next question is usually a practical one. The guide to suing Experian for a credit report error explains when a failed investigation becomes an FCRA claim, what you can recover, and how long you have to bring it. The same analysis applies at the other two national bureaus: here is when you can sue Equifax for a credit report error, and what it takes to bring a claim for a TransUnion error that survived your dispute.