Dun and Bradstreet: The FTC Found the Business Credit Reporting Giant Failed to Maintain Adequate Accuracy in Its Small Business Credit Files

Dun and Bradstreet Corporation, the dominant provider of commercial credit reporting and business information services in the United States, reached a Federal Trade Commission settlement resolving charges that the company had failed to maintain reasonable procedures to ensure the accuracy of the information it compiles and reports in commercial credit files — errors that affected small businesses' ability to access financing, obtain favorable insurance terms, win vendor partnerships, and pursue other commercial opportunities that depend on accurate business credit data.DOCUMENTED

The FTC's case against Dun and Bradstreet addressed an asymmetry in commercial credit reporting that is less well-known than the consumer credit reporting framework: unlike the Fair Credit Reporting Act's protections for individual consumers, which include explicit rights to dispute inaccurate information and have it corrected, the regulatory framework governing commercial credit reporting has historically provided less robust mechanisms for small businesses to identify and challenge errors in their commercial credit files — a gap that the FTC's investigation found had allowed inaccuracies to persist and to harm businesses that had no effective recourse.

The Role of Business Credit Reporting

Commercial credit reports compiled by Dun and Bradstreet — including the Paydex score and DUNS-based credit assessments — are used by a wide range of commercial counterparties to evaluate the creditworthiness and reliability of businesses they are considering extending credit to, insuring, partnering with, or accepting as suppliers or customers. A lender evaluating a small business loan application, an insurer writing a commercial policy, a large corporation establishing a supplier relationship, or a vendor setting credit terms for a new customer may all consult Dun and Bradstreet data as part of their evaluation — making the accuracy of that data directly relevant to the small business's commercial opportunities across multiple dimensions simultaneously.REVIEWED

Unlike consumer credit, which in the United States is governed by a comprehensive federal regulatory framework that specifies accuracy requirements, dispute rights, and enforcement mechanisms, commercial credit reporting operates under less prescriptive oversight. While the FTC has authority under its general unfair and deceptive practices powers to address inadequate accuracy practices in commercial credit reporting, there is no equivalent to the Fair Credit Reporting Act establishing specific rights and obligations in the commercial context. This regulatory gap has meant that accuracy failures in commercial credit files have historically been harder for affected businesses to identify, challenge, and have corrected than equivalent errors in consumer credit reports.DOCUMENTED

The Accuracy Failures and Their Commercial Consequences

The FTC's investigation identified categories of accuracy failure in Dun and Bradstreet's commercial credit files that reflected inadequate data collection, verification, and quality control procedures. These included trade line information — records of how businesses have paid their suppliers and creditors — that was incorrectly attributed to businesses, reported with incorrect dollar amounts, or that reflected payment experiences from other entities that had been incorrectly linked to the subject business's file. For a small business with a limited credit history, a single incorrectly attributed negative trade line — a payment record from another company linked to their DUNS number — can materially affect their creditworthiness assessment and block access to financing or business opportunities they would otherwise qualify for.REVIEWED

The consequences of commercial credit errors are particularly significant for small businesses because they often lack the relationship capital, alternative credit history, and negotiating leverage that larger businesses can use to work around credit data problems. A large corporation with a decades-long banking relationship can often address a credit file error through direct communication with its lender. A small business seeking its first SBA loan, a new vendor relationship, or commercial insurance may find that the inaccurate credit file is disqualifying without any practical mechanism for identifying the error or having it corrected before a decision is made.

A wrong trade line in a small business's credit file is not a data point. For a company trying to get its first line of credit or pass a vendor qualification check, it is a closed door — and the business owner often has no idea the error is there until the rejection arrives.

Dispute Mechanisms and Business Rights

One dimension of the FTC's enforcement action addressed the inadequacy of Dun and Bradstreet's dispute resolution mechanisms for businesses that identified errors in their commercial credit files. Unlike the FCRA's prescribed dispute process — which requires consumer credit bureaus to investigate disputes, correct verified errors, and notify consumers of the outcome within specific timeframes — the commercial credit dispute process has been less structured, with the time required to resolve disputes and the outcome of those disputes often dependent on the company's internal practices rather than on regulatory requirements. The FTC's settlement required Dun and Bradstreet to implement improved dispute resolution procedures that give businesses more reliable and timely means of identifying and correcting errors in their commercial credit files.DOCUMENTED

For small businesses that believe their Dun and Bradstreet files may contain errors, the practical steps available include: establishing a DUNS number and claiming the associated business profile on the Dun and Bradstreet platform, reviewing the file for inaccurate or incorrectly attributed information, and initiating disputes for any errors identified. The post-settlement improvements to Dun and Bradstreet's dispute process are intended to make these steps more effective and timely — but businesses should not assume that commercial credit files are accurate without review, particularly if they are preparing to apply for financing, seek new vendor relationships, or pursue other commercial opportunities where commercial credit information will be evaluated.

The Broader Commercial Credit Accuracy Framework

The FTC's enforcement against Dun and Bradstreet has been cited as support for legislative and regulatory proposals to extend more FCRA-like accuracy and dispute rights to commercial credit reporting — a policy debate that has gained momentum as small business owners have become more aware of commercial credit reporting and more vocal about the accuracy and fairness of the current system. A regulatory framework that established specific accuracy requirements, dispute rights, and remediation timelines for commercial credit reporting would provide small businesses with the tools to protect themselves from the kind of data accuracy failures the FTC identified in the Dun and Bradstreet case — and would establish the same accountability mechanisms for commercial credit that have been in place for consumer credit for decades.

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