XCFCRA / FDCPA Dispute States

    Compliance Condition Code XC: FCRA Investigation Complete - Consumer Disagrees

    Compliance Condition Code XC means "FCRA Investigation Complete - Consumer Disagrees". You finished investigating a direct FCRA or FDCPA dispute and concluded the data was accurate, but the consumer still maintains it is wrong. It is reported in Compliance Condition Code (Field 32) of the Base Segment, 2 characters at position 215.

    Specification

    CodeXC
    MeaningFCRA Investigation Complete - Consumer Disagrees
    FieldCompliance Condition Code (Field 32)
    RecordBase Segment
    Length / position2 chars · 215216
    CategoryFCRA / FDCPA Dispute States
    CRRG referenceCRRG Exhibit 8 (Compliance Condition Codes)

    What Compliance Condition Code XC means

    • The terminal state of a direct dispute you did not resolve in the consumer's favour.
    • Says two things at once: your investigation is closed, and the disagreement is unresolved.
    • Use it only after a real investigation. Moving from XB to XC without reviewing the account is precisely the conduct the FCRA's reasonable-investigation standard exists to prevent.
    • The consumer retains the right to add a statement of dispute at the bureau; that is handled by the bureau, not by the furnisher's file.

    When to report XC

    • 1A consumer disputes a 60-day delinquency, your records show the payment was late, and the consumer still disagrees.
    • 2A consumer says an account is not theirs, identity verification confirms it is, and the consumer maintains the dispute.
    • 3A borrower disputes a charge-off amount, the amount reconciles to your ledger, and no agreement is reached.

    Reporting rules

    • Report XC only after the investigation has actually concluded.
    • Document what you reviewed and when. The documentation burden sits with the furnisher.
    • If the consumer later accepts the outcome or drops the dispute, clear the condition with XR.
    • If your investigation shows the data was wrong, correct the data and report XH rather than XC.

    Codes and fields that must agree

    A file can be structurally valid and still be wrong. These are the cross-field conditions Compliance Condition Code XC has to satisfy.

    • Follows XB. Reporting XC without a prior XB implies an investigation with no dispute to investigate.
    • If the account is also closed at the consumer's request, report XE instead.
    • Cleared only by XR or by overwriting with another compliance condition code.

    Common errors involving XC

    Vocabulary

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    Source: CRRG Exhibit 8 (Compliance Condition Codes). Last reviewed 2026-08-25.

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    Metro 2 Compliance Condition Code XC: FCRA Investigation Complete - Consumer Disagrees