David Schultz Analyzes in ARM Compliance Digest: Judge Grants Motion for Summary Judgement for Defendant in FCRA Case Over Disputed Debt Investigation
In The News | 2 min read
Dec 23, 2022
In the December 19, 2022 edition of the ARM Compliance Digest, Hinshaw partner David Schultz discussed lessons learned from an Arizona District Court judge's decision to grant a defendant’s motion for summary judgment in a Fair Credit Reporting Act (FCRA) case. Schultz stated:
Sanchez v JPMorgan Chase hits on many of the issues that arise in a challenge to a tradeline. The court spends 18 pages doing a nice analysis of FCRA law on disputes, ultimately ruling for the furnisher. The basic facts are that JPMorgan Chase accepted a small payment to resolve a debt. It then reported a $0.00 balance, that it was 120 days delinquent, and that it was settled for less than the full balance. Plaintiff disputed the report but was a bit vague on the grounds. Chase investigated the matter and kept reporting a payment rating of 120 – 149 days past due. This FCRA suit followed.
Plaintiff claimed that payment rating was not proper. The court disagreed. It said that it is neither patently inaccurate nor materially misleading. The court said the tradeline must be viewed in its entirety. When “Pay Status” is looked at in conjunction with the rest of the tradeline, it is clear that the tradeline is reporting a historical pay status. The tradeline lists a zero balance, states a last payment in September of 2018, notes it was closed in 2018, and it settled for less than the full balance.
Once the court determined that the information was not patently incorrect or materially misleading, it moved on to review whether the investigation was reasonable. Chase showed that it reviewed its internal notes and verified the account status, the payment rating, and the account history. It verified the accuracy of the dates opened, last payment, and account closure. It insured it was reporting consistent with Metro 2 standards. The court concluded the investigation was reasonable.
The case presents a nice analysis on the standards to address in a tradeline dispute case. The insight into Chase’s investigation is also helpful for furnishers.
"Judge Grants MSJ For Defendant in FCRA Case Over Disputed Debt Investigation" ARM Compliance Digest, December 19, 2022.
Read the full December 19, 2022 edition of the AccountsRecovery.net Compliance Digest.
Related People
Related Capabilities
Related Locations
Featured Insights

Press Release
Nov 13, 2026
Hinshaw Advises Client Safe Harbor Capital Partners in $44 Million Financing

In The News
Nov 12, 2026
Spencer Kook Authors Article Providing a Claims Manager’s Guide to Class Action Exposure

In The News
Nov 12, 2026
Mitch Chargo Discusses Cannabis M&A Implications in a Post-Rescheduling Landscape

Webinar
Nov 12, 2026
Michael Adams Presents on Navigating Ethics in the Digital Age

Event
Nov 12, 2026
Cathy Mulrow-Peattie Discusses AI and Supply Chain Cybersecurity

Healthcare Alert
Nov 11, 2026
Illinois Enacts 340B Contract Pharmacy Protections: 7 Steps Covered Entities Should Take

In The News
Nov 10, 2026
Brian Turetsky Examines How NYC’s Proposed POWER Act Could Expand Private UDAAP Claims

In The News
Nov 9, 2026
Kate Schnake Examines Unlawful Discrimination vs. Legitimate Advocacy in Jury Selection

Press Release
Nov 6, 2026
Hinshaw Recognized by the LCLD as a 2026 Compass Award Winner and Top Performer

Consumer Crossroads: Where Financial Services and Litigation Intersect
Nov 5, 2026
FDIC Proposes State Bank Preemption Parity Rule Regarding Host State Laws



