FCRA 604: The Truth About “Breach,” Deletions, and Why Stuff Disappears Then Comes Back
- SUPPORT
- Nov 11, 2025
- 9 min read
You’ve probably seen some version of this online:
“Hit them with a 604 letter.They can only report after a breach.If they pulled before the breach, it’s illegal — they have to delete it.”
And then the follow-up horror story:
“It got deleted… then came back a few months later. What the hell?”
So let’s clear this up properly:
What FCRA Section 604 actually says
How “breach” really fits into permissible purpose
Why some items get deleted and then reinserted
How to use 604 the right way inside a serious, collector-first system (not as a magic spell)
This is education, not legal advice. If you think you’ve got a real 604 case, you talk to a consumer law attorney. But you at least deserve to know what’s real and what’s influencer fanfic.
1. What FCRA Section 604 Actually Is (No Myth Version)
“Section 604” is just the old section number in the Fair Credit Reporting Act. In the U.S. Code, it’s 15 U.S.C. § 1681b. It’s the part that tells credit bureaus and users:
When are you allowed to pull and use a consumer report — and when are you absolutely not?
This is called “permissible purpose.”
Under 604, a consumer reporting agency (Experian, TransUnion, Equifax, etc.) may only provide a consumer report in certain situations, including: Legal Information Institute+2Experian+2
Court order or federal grand jury subpoena
Written instructions from the consumer
In connection with credit:
Application for credit
Review of an existing account
Collection of an account
Employment purposes (with written consent)
Insurance underwriting after an application
Licensing / government benefit that requires checking financial responsibility
Legitimate business need in connection with a transaction the consumer initiated, or to review an account
And 604(f) is blunt: no one is allowed to get a report without a permissible purpose. Consumer Financial Protection Bureau+1
So 604 is not “the delete button.”It’s the rulebook for when they’re even allowed to look at your file.
2. Where the “Breach” Myth Comes From (and Why It’s Half-Wrong)
On social, you’ll hear:
“They can only pull your report after a breach. So if they pulled before you defaulted, that’s a 604 violation — instant deletion.”
Nope.
Here’s what the law actually allows:
They can pull your report when:
You apply for credit (pre-breach)
They are reviewing your account to see if you still qualify under terms (pre- or post-breach)
They are trying to collect a delinquent account (post-breach)Legal Information Institute+1
In other words, 604 does NOT say “only after breach.”
It says “only for specific, lawful reasons,” and those reasons definitely include:
Before you ever miss a payment (when you applied)
While your account is current (account review)
After you default (collection)
Where “breach” really comes in is this:
If there is no application,
No existing account,
No legit collection effort,
No court order or other permissible purpose…
…and somebody pulls or uses your report anyway?
Now you’re talking 604 problems.
Examples where “post-breach” or “attached to breach” logic actually matters:
A lender keeps pulling your report long after the account is closed and discharged, claiming “account review” when there is no account anymore. CrossCheck Compliance LLC
A collector pulls your credit when they have no assigned account connected to you — no contract, no debt they can show.
A landlord keeps pulling reports during a lease when there’s no default, no new transaction, and no genuine business need tied to the lease.
But “they pulled it when I applied” or “they reviewed my existing account before I defaulted” is not a 604 violation. That’s literally one of the main permissible purposes listed in the statute. Legal Information Institute+1
3. What a Real 604 Violation Looks Like
If you want to use 604 in a serious way, you have to ask one question:
“What exact purpose did they have when they pulled this report, and does that purpose match something actually listed in §1681b?”
Legit examples (usually OK):
You applied for a card → they pulled your personal report.
You already have a card with them → they do periodic account reviews.
Your account is charged off → a collector pulls your report to collect.
You applied for a job → employer pulls your report with written consent. Legal Information Institute+1
Shady / potentially impermissible examples:
An old landlord pulls a fresh report even though:
You’re long gone or the lease is done
There’s no collection, no new application
A random collector you’ve never heard of pulls your file but can’t tie it to:
A specific account
A legitimate assignment
A business pulls your report to “see if they want to market to you” without a firm offer or your permission (pre-screen rules exist, but they’re tight). Legal Information Institute+1
The CFPB’s 2022 advisory hammered this: the purposes under 604 must be consumer-specific, and CRAs can’t just blast data out on vibes and disclaimers. Consumer Financial Protection Bureau+1
So yeah, 604 is powerful — if the facts actually line up with an impermissible purpose.
4. “I Hit Them With 604, It Got Deleted… Then It Came Back.”
Let’s talk about the part that drives people crazy.
You send a hard 604 letter.Something gets deleted from your reports.You celebrate.Then a few months later, it’s back.
What happened?
4.1. Deletion is not always “they admitted guilt”
Sometimes, something comes off your report because:
The furnisher didn’t respond in time
The CRA couldn’t verify during that investigation window
The CRA just temporarily suppressed it while they “figure it out”
Under the FCRA’s dispute rules (§611 / 15 U.S.C. §1681i), if the bureau can’t verify an item in the time allowed, they have to delete or modify it. Federal Trade Commission
That does not automatically mean:
“This is illegal forever, they can never touch this again.”
It means:
“Right now, we can’t verify this, so it’s gone. For now.”
4.2. Reinsertion rules: how deleted stuff comes back legally
The FCRA actually has a section on reinsertion:
If a CRA deletes an item because it “couldn’t be verified”…
That item can only be reinserted if the furnisher later certifies the information is complete and accurate.
And if they do reinsert it, the CRA has to notify you within a short window (usually 5 business days). Federal Trade Commission
So the pattern you’re seeing might be:
You send a 604 / dispute letter.
Furnisher blows off the first investigation → CRA deletes.
Later, furnisher wakes up, sends in paperwork, certifies accuracy.
CRA re-adds the tradeline or inquiry and mails you a notice (that you might ignore or never receive).
You didn’t imagine the deletion.But you also didn’t build a permanent wall; you triggered a temporary win while the other side was asleep.
4.3. When reinsertion might be a problem
Reinsertion becomes sketchy if:
No certification ever happened; or
The CRA never notifies you after putting it back on; or
The information being reinserted is still clearly inaccurate or untied to any permissible purpose.
That’s when a well-documented 604 + 611 combo (permissible purpose + dispute / reinsertion) can actually become enforcement leverage — the kind of thing Formula 2.0 at Dareshore is designed to surface.
But you only know that if:
You keep copies of your letters
You track dates
You open the mail
You treat this like a file, not “manifesting”
5. “It Has to Be Attached to a Breach and After”: What That Really Means
Let’s translate that line into plain English and THEN fix it.
The idea people are trying to get at is:
“You can’t just be pulling my credit randomly with no contract, no default, no active relationship. There has to be a legit trigger.”
That part is emotionally true, but legally it’s narrower.
5.1. There has to be a real transaction or obligation
FCRA 604 is clear: the report has to be tied to one of the listed purposes — things like:
Application for credit
Review of an existing account
Collection of a debt tied to you
Employment (with consent)
Insurance or licensing decisions
Legit business need tied to a transaction you initiated Legal Information Institute+2Experian+2
If there is no account, no transaction, no collection, no application, no order, no consent, then yeah — pulling your report starts looking like a 604(f) problem: using or obtaining a report without permissible purpose. Consumer Financial Protection Bureau+1
That’s where you see real 604 lawsuits.
5.2. But “after breach only” is not what the law says
The law never says:
“You can only pull or report after a breach.”
Creditors are allowed to:
Pull at application (before anything goes wrong)
Pull for account review, to see if you still qualify
Pull in connection with collection after you default
So the “attached to breach and after” line is a bad oversimplification.
Better, more accurate frame:
“Any pull or ongoing reporting has to be tied to a real, lawful purpose under §1681b — not vibes, not curiosity, not harassment, not marketing without following the pre-screen rules.”
And that’s where a lot of collector-first, violation-driven systems (like the Dareshore / Formula 2.0 setup) live: not in fantasy land, but in actual permissible-purpose analysis.
6. How a Serious 604 Strategy Fits Inside Collector-First / Formula 2.0
If you want to use 604 like a grown-up instead of playing TikTok lawyer, here’s what that looks like in a collector-first workflow.
Step 1: Pull your full file and inquiry list
Get all three reports, not just a score app.
Look at:
Hard inquiries (who pulled what, when)
Soft inquiries (for context)
Tradelines tied to collections / charge-offs
Build a log:
Furnisher / company name
Date of pull or first report
What relationship (if any) you had with them at that time
Step 2: Ask yourself the real question
For each pull / tradeline:
“What plausible permissible purpose did they have on that date?”
Some will be obvious:
You applied for a card → they pulled your report.
You had an existing card → they did account review.
You defaulted → a collector pulled your file while trying to collect.
Others will feel off:
You never applied with that company, ever.
You had no open accounts with them at the time.
They can’t tie the pull to any obligation or transaction you initiated.
Those “off” ones are where 604 starts getting interesting.
Step 3: Paper it – politely, precisely
Instead of screaming “604 VIOLATION PAY ME MILLIONS,” you write in a way that looks sane if a regulator or judge ever reads it.
For inquiries or reporting you believe are impermissible:
Ask the CRA for:
The certified permissible purpose for the pull,
The name of the entity, and
Any code they used (credit, collection, employment, etc.). Experian+1
Ask the puller/furnisher directly:
What account or transaction this pull was connected to
What section of the FCRA they believe authorizes it
To delete the inquiry / tradeline if they cannot substantiate permissible purpose
You’re not begging. You’re forcing them to commit to a story on paper.
Step 4: Combine 604 with 611 / reinsertion logic
If:
They can’t justify the permissible purpose;
Or the CRA drops the item after a dispute;
Or something deleted suddenly reappears without proper certification and notice…
…now you’re looking at a stack of potential issues:
604 (impermissible use) Legal Information Institute+1
611 (failure to handle disputes / reinsertion properly) Federal Trade Commission
Possibly other duties under FCRA and related regs
That’s exactly the kind of layered pattern a big violations engine (the 1,244-point + 57 internal errors structure Dareshore talks about) is built to map — instead of you guessing in the dark.
Step 5: Decide your play
A serious 604-informed path can look like:
Clean deletions for clearly impermissible pulls
Pressure on furnishers to stop pulling / reporting without a real purpose
Stronger bureau disputes backed by actual law and facts
If justified and with legal help, possible claims for impermissible access
Notice what it’s not:
It’s not “use 604 to delete any negative account you don’t like.”
It’s not “everything must be attached to breach after the fact or it’s illegal.”
It’s not “one letter and you’re a millionaire.”
7. Red Flags: When 604 Is Being Used as Bait
If you see any of this, your scam radar should start screaming:
“We use 604 to delete any collection or charge-off, guaranteed.”
“We’ll show you how to sue every creditor for pulling your report before default.”
“All inquiries are illegal under 604 unless they delete them when you demand.”
Real talk:
Many pulls are legal, even if you hate them.
Many collections are tied to legitimate contracts and defaults.
You can’t convert “I’m mad” into “it’s illegal” just by writing “Section 604” in all caps.
A legit 604-aware strategy:
Admits that accurate, properly-sourced negative info can be reported.
Focuses on situations where permissible purpose is genuinely missing or abused.
Uses 604 as one piece of a bigger collector-first, violation-driven system — not the whole religion.
That’s why the Dareshore ecosystem keeps hammering:
Collector-first, not bureau-only
Facts + law + procedure, not vibes
System, not “secret letter”
8. What to Do If You Suspect a Real 604 Issue
If you’re seeing weird inquiries or reporting and your gut says “this makes no sense,” here’s a grounded path:
Pull full reports and make a list of every unknown / sketchy pull.
Ask the bureaus (in writing) for the certified purpose and furnisher details for those pulls. Experian+1
Ask the company that pulled the report to identify:
The account/transaction
The permissible purpose they relied on
If they can’t give a straight answer and keep playing with your file:
Dispute the inquiry / tradeline as impermissible
Document everything (letters, dates, responses)
If you’ve got clear evidence they pulled or used your report with no permissible purpose, and especially if you took damage from it:
That’s when it’s worth speaking with a consumer law attorney who handles FCRA work.
All of this hits way harder when you’re not winging it, but running inside a structured, collector-first system. That’s literally what Formula 2.0 at Dareshore.com is described as: a way to turn laws + violations + procedures into an organized plan instead of random shots in the dark.
Bottom line?
604 is real.
Permissible purpose is real.
Impermissible pulls are a real problem.
But “it has to be attached to breach and only after” is not what the statute says, and it’s not how the courts or regulators read it.
If an item gets removed then comes back, that doesn’t mean 604 doesn’t work. It means:
You poked the system,
Someone woke up on their side,
And now it’s time to stop playing template games and start working with an actual plan.
Use 604 like a scalpel, not a meme.
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