In Gross v. Citimortgage (9th Cir. 2022) — FCRA decision, No. 20-17160, 2022 U.S. App. LEXIS 13096, at *8 (9th Cir. May 16, 2022), the Court of Appeals for the 9th Circuit held that under the FCRA, a furnisher of credit information must make a reasonable investigation if the consumer about whom it furnishes information to a credit reporting bureau properly protests the inaccuracy of the furnisher’s information. Furnishers may be required to investigate the legal as well as factual bases of the information it furnishes. Here, the furnisher continued to report information about plaintiff’s second mortgage after the foreclosure of his first mortgage eliminated his personal liability for the second mortgage debt under applicable Arizona law. Whether the furnisher’s investigation was reasonable in light of that clear legal rule was an issue for the jury to decide.