The following is a summary of a recent federal court ruling addressing this question:
In Longman v. Wachovia Bank, the Connecticut District Court held that the consumer's state law defamation claim was preempted by the Fair Credit Reporting Act (the "FCRA"). The consumer had alleged Wachovia defamed him by falsely reporting information to the consumer reporting agencies (the "CRAs") related to a three-year balloon lot note which he had obtained to finance a land purchase from Wachovia. The Court found, among other things, that Section 1681t(B)(1)(F) of the FCRA expressly preempts the application of state law regarding any matters regulated by Section 1681s-2. The Court reasoned that because the consumer alleged Wachovia reported this false information to the agencies, he was necessarily asserting a violation of Section 1681s-2, the Section of the FCRA which in part governs the reporting of information to the CRAs.
Therefore, according to this Connecticut District Court a consumer may not claim state law defamation against a furnisher of inaccurate credit information since that claim would be preempted by the FCRA.
HOWEVER, all is not lost. To sue a furnisher for reporting inaccurate information on your credit report, you simply need to dispute that information through the credit reporting agencies. And then, if the inaccurate information is not corrected, you may file suit under the FCRA.