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Michigan Federal Court Grants Summary Judgment to Creditor on Standing Grounds in Case Alleging FDCPA Violation for Failure to...

On September 7, the U.S. District Court for the Eastern District of Michigan granted summary judgment in the defendant’s favor finding that the plaintiff had not suffered a concrete injury and therefore lacked standing to...more

Seventh Circuit Finds Furnisher Not Liable Under FCRA Despite CRA’s Inaccurate Interpretation of Furnisher’s Reporting

In Frazier v. Dovenmuehle Mortgage, Inc., the Seventh Circuit recently issued an opinion affirming summary judgement in favor of the defendant data furnisher in a suit brought by a consumer under § 1681s-2(b) of the Fair...more

Washington Federal Court Reiterates Distinction Between Furnishers’ and CRAs’ FCRA Investigatory Obligations and the Necessity of...

A district court in the Western District of Washington held that the Fair Credit Reporting Act (FCRA) does not require a consumer reporting agency (CRA), as part of its investigative duties, to issue an opinion on the legal...more

What We Learned From 2022’s Top FCRA Developments

The Fair Credit Reporting Act saw no shortage of activity in 2022. That activity included judicial decisions, regulatory actions, and federal and state legislation. As we reflect on certain significant developments from the...more

No FCRA Violations Found Where Defendants Promptly Corrected Inaccurate Data and Updated Plaintiffs’ Consumer Report

In a recent decision, the U.S. District Court for the Eastern District of Pennsylvania granted summary judgment in a Fair Credit Reporting Act (FCRA) case where a bank promptly corrected inaccurate mortgage payment...more

Federal District Court Grants Summary Judgment Dismissing Claim that Creditor Conducted an Unreasonable Investigation of a FCRA...

In Suluki v. Credit One Bank, N.A. (Credit One), the Southern District of New York recently granted summary judgement to a creditor in a suit alleging violations of the Fair Credit Reporting Act (FCRA) for failure to conduct...more

Double Reporting Leads to Denial of Summary Judgment in Illinois FCRA Case

An Illinois federal district court recently denied a creditor-defendant’s motion for summary judgment in a Fair Credit Reporting Act (FCRA) case brought by a consumer who questioned why his debt was being reported twice — as...more

FTC Orders Small Business Credit Reporting Companies to Disclose Information About Industry

The Federal Trade Commission (FTC) announced that it is launching an inquiry into the small business credit reporting industry. Specifically, it is ordering five firms to provide detailed information about their products and...more

The CFPB and FTC Continue to Focus on Tenant Screening

On February 28, the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) jointly issued a Request for Information, seeking public comment on how background screening affects individuals seeking...more

TransUnion In “Active Settlement Discussions” with CFPB and FTC Over Tenant Screening

On February 14, TransUnion filed its annual 10-K report pursuant to the Securities and Exchange Act. Under the section entitled “Risks Related to Laws, Regulations and Government Oversight,” the company disclosed that it was...more

U.S. House Bill Proposes Excluding Pandemic Evictions From Consumer Reports

On January 20, Representative Steve Cohen (D-Tenn) introduced the Keeping Evictions Off Credit Reports Act, H.R. 1594, in the U.S. House of Representatives seeking to prohibit evictions due to the COVID-19 pandemic from...more

Second Circuit Holds No FCRA Violation When Dischargeability of Debt is a Legal Question

Should credit reporting agencies (CRAs) be held liable under the Fair Credit Reporting Act (FCRA) for alleged reporting inaccuracies that turn on legal disputes? According to the Second Circuit in a recent decision, the...more

Ramirez Case Reaches Final Approval of Class Settlement

On December 15, 2022, the parties in TransUnion LLC v. Ramirez — a case that went all the way to the Supreme Court in 2021 to resolve questions of Article III standing — obtained final approval of their class settlement...more

CFPB Highlights Purported “Problems With Tenant Background Checks”

On November 15, the Consumer Financial Protection Bureau (CFPB) issued two reports, highlighting what the CFPB perceives to be forms of errors that frequently occur in tenant background checks and the impacts the CFPB...more

CPFB Issues Final Rule for Credit Reporting for Survivors of Human Trafficking

On June 23, the Consumer Financial Protection Bureau (CFPB) issued a final rule, prohibiting consumer reporting agencies (CRAs) from reporting adverse information resulting from human trafficking on survivors’ credit reports....more

Keeping Up With the Bureau Episode 2: FCRA Preemption Issues, Infringing State Laws, and the CFPB's Position [Audio]

Please join Consumer Financial Services Partner Kim Phan and her guests and colleagues Alan Wingfield and David Anthony in the second episode of a special four-part series on recent developments with the Consumer Financial...more

Third Circuit Adopts “Reasonable Reader” Standard for Evaluating Whether a Credit Report Is Inaccurate or Misleading

What standard should courts use to determine whether information contained in a consumer’s credit report is inaccurate or misleading? According to the Third Circuit in a recent precedential decision, the standard should be...more

Consumer Reporting Trade Association Defeats Antitrust Claim: Court Held Plaintiff Lacked Standing and Failed to Allege...

On February 28, the U.S. District Court for the Southern District of New York dismissed a case brought against the Consumer Data Industry Association (CDIA) under federal antitrust law. The case alleged that the CDIA — a...more

Eastern District of Pennsylvania Analyzes CRA Definition Under the FCRA

On February 25, the U.S. District Court for the Eastern District of Pennsylvania held that a purported public records vendor (Credit Lenders Service Agency or CLSA) is a consumer reporting agency (CRA) under the Fair Credit...more

CFPB Addresses Credit Reporting in Buy Now Pay, Later Market

In a blog post released June 15, the Consumer Financial Protection Bureau (CFPB) continued to show its interest in credit reporting by Buy Now, Pay Later (BNPL) lenders. Recognizing the importance of credit reporting to...more

FTC and CFPB Join Forces on Amicus Brief Arguing That FCRA Does Not Distinguish Between Legal and Factual Inaccuracy

On May 5, the Consumer Financial Protection Bureau (CFPB or Bureau) and the Federal Trade Commission (FTC) together filed an amicus brief in an appeal pending before the Court of Appeals for the Second Circuit, Sessa v. Trans...more

CFPB Argues the FCRA Requires Furnishers to Investigate Legal Issues Raised in Consumer Disputes

On April 7, the Consumer Finance Protection Bureau (CFPB or Bureau) filed an amicus brief in an appeal, pending before the Court of Appeals for the Eleventh Circuit in which the Bureau argued that the Fair Credit Reporting...more

Key Takeaways From the New Onslaught of FCRA Filings

Following an unprecedented year, lawsuits under the Fair Credit Reporting Act continue to be filed with ever-increasing frequency and consequence. Originally published in Law360 on January 28, 2022. ...more

FCRA Litigation: A Look Ahead for 2022 - FCRA Focus Podcast [Audio]

Join Troutman Pepper Consumer Financial Services Partner Dave Gettings for a special podcast series dedicated to exploring the Fair Credit Reporting Act (FCRA). In this inaugural episode, Dave talks with fellow Troutman...more

Democratic Senators Urge CFPB to Take Action on Credit Reporting Errors

On November 10, a group of Democratic senators sent a letter to Consumer Finance Protection Bureau (CFPB) Director Rohit Chopra, requesting that the CFPB take a proactive stance in its regulation of consumer reporting...more

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