The Federal Trade Commission has published commentary regarding § 1681e(b) compliance in the Code of Federal Regulations. The commentary provides that while credit reporting agencies can rely on furnishers of information that it reasonably believes to be reputable, once it learns or should reasonably be aware of errors in its reports that may indicate systematic problems (by virtue of information from consumers, report users, from periodic review of its reporting system, or otherwise) it must review its procedures for assuring accuracy.” 16 C.F.R.Part 600 App.

The commentary further provides that “[a] consumer reporting agency must also adopt reasonable procedures to eliminate systematic errors that it knows about, or should reasonably be aware of, resulting from procedures followed by its sources of information. For example, if a particular credit grantor has often furnished a significant amount of erroneous consumer account information, the agency must require the creditor to revise its procedures to correct whatever problems cause the errors or stop reporting information from that creditor.”
16 C.F.R. Part 600 App.

The commentary recognizes that a credit reporting agency’s “[r]equirements are more stringent where the information furnished appears implausible or inconsistent, or where procedures for furnishing it seem likely to result in inaccuracies, or where the consumer reporting agency has had numerous problems regarding information from a particular source.” 16 C.F.R. Part 600 App.