Why Correcting the File Is Not Enough

This chapter examines what happens after a disputed tenant-screening item changes: whether the event is still legally reportable, whether its disposition is visible, and whether the landlord or property manager receives the update in a usable form. The practical judgment is that a correction is not complete merely because a field changed inside RentGrow. The report, the screening result, and the message sent to the housing decision-maker are related states, but they are not the same state.

That distinction matters because court information is not static. A charge can be dismissed. An eviction proceeding can acquire a judgment or another disposition. A record can be sealed or expunged. A reporting period can expire even though the event remains in an old database. And a correction can be made after a landlord has already received a report. A screening system that treats the first collected version as permanent can become inaccurate even when it initially matched the right record.

Status changes what a record means

The CFPB’s advisory opinion interprets the FCRA’s accuracy requirement to include available disposition information when a consumer reporting agency reports arrests, criminal charges, eviction proceedings, or other court filings. A filing without its result can be misleading because the result changes what the event means. Reporting that a person faced a charge without showing that it was dismissed gives the reader a different account from reporting the charge together with its disposition. The same principle applies to an eviction proceeding whose later outcome changes how the initial filing should be understood.

Disposition is therefore not decorative metadata. It is part of the event being reported. A report that names the initial filing but omits a dismissal may leave the customer with the impression that the adverse event remains unresolved. A report that lists a bankruptcy filing without a discharge can omit the fact that the proceeding reached a materially different state. The CFPB uses these examples to explain why a reporting agency needs procedures to find and include available dispositions, not merely procedures to retrieve the first adverse entry.

Legal accessibility creates a second status boundary. The CFPB says a consumer reporting agency should not include records that have been expunged, sealed, or otherwise legally restricted from public access in a way that prevents the report user from obtaining them directly from the government entity that maintains the record. Expungement removes or destroys a matter from the public record; sealing removes it from public view. Other legal rules can restrict access to records after specified conditions. The exact rule can depend on the jurisdiction and the type of record, so the advisory opinion does not turn every old or private record into one universal category.

The point is functional. If the landlord or property manager could not obtain the matter directly from the government recordkeeper because the record is legally restricted, including it in a consumer report can present the applicant’s background as containing a publicly available fact that the user is not actually entitled to see. The report would not merely be out of date. It would describe the person using information whose legal status has changed.

Time limits add another dimension. The CFPB explains that the FCRA generally bars reporting certain adverse information more than seven years after the adverse item, with statutory exceptions such as records of convictions of crimes. The period generally begins with the adverse event itself.