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Federal Court Grants Summary Judgment Holding Reporting of Loan During COVID-19 Forbearance as Accurate

In December 2021, a federal judge granted a motion for summary judgment in Mitchell v. Specialized Loan Servicing LLC, holding that defendant Specialized Loan Servicing LLC (Specialized Loan) properly reported plaintiff Eric...more

Ninth Circuit Affirms Summary Judgment for CRA in Seven-Year Look-Back Case

On February 10, the Ninth Circuit affirmed a Central District of California decision, finding that a consumer reporting agency (CRA) did not violate the Fair Credit Reporting Act (FCRA) when it reported a criminal record with...more

Year-End Report Reveals Continuing Trend of Increased FCRA Filings in 2021

According to a recent year-in-review report by WebRecon, Fair Credit Reporting Act (FCRA) filings continued their upward trajectory throughout 2021. This stands in contrast to filings under the Fair Debt Collection Practices...more

FTC Settlement with Lead Generator Enumerates FCRA and Privacy Requirements for Lead Sales

A recent settlement between the Federal Trade Commission (FTC) and a lead generator provides new insight into the FTC’s enforcement of sensitive personal data collection and sales under the Fair Credit Reporting Act (FCRA)...more

CFPB Issues Advisory Opinion on Name-Only Matching

On November 4, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion, stating that a consumer reporting agency (CRA) that engages in name-only matching violates the Fair Credit Reporting Act’s (FCRA)...more

CFPB Reports Consumers in Minority Neighborhoods More Likely to Have Disputes on Credit Report

In a report released on November 2, the Consumer Financial Protection Bureau (CFPB) found that credit report disputes more commonly occur among consumers in majority Black and Hispanic neighborhoods than consumers in majority...more

DC Circuit Found Waiver of Sovereign Immunity Under FCRA and FMCSA Is Not a CRA

In Mowrer v. United States Department of Transportation, the U.S. Court of Appeals for the District of Columbia held that government immunity is waived under the FCRA, but also found that the Federal Motor Carrier Safety...more

First Circuit Affirms Final Approval of FCRA Class Action Settlement

In Robinson v. Nat’l Student Clearinghouse, — F.4th — (1st Cir. 2021), a First Circuit panel unanimously affirmed the district court’s Final Approval Order, approving the class settlement in an action brought under the Fair...more

District Court’s FCRA Decision Offers Guidance for Employers on “Clear and Conspicuous” Disclosures and Willfulness

After the District Court for the District of Oregon dismissed a Fair Credit Reporting Act (FCRA) suit filed against Fred Meyer, Inc., the Ninth Circuit Court of Appeals partially reversed, holding Fred Meyer had failed to...more

CFPB to Furnishers of Information to Consumer Reporting Agencies: Have an Adequate Written Policy or Else

On August 16, the Consumer Financial Protection Bureau (CFPB) filed a proposed settlement to resolve a lawsuit against a debt collection firm, Fair Collections & Outsourcing (FCO), and its owner, Michael Sobota, stemming from...more

Supreme Court Decision: TransUnion v. Ramirez

Today, the Supreme Court issued its opinion in TransUnion LLC v. Ramirez, holding that a concrete injury requires more than the existence of a risk of harm that never materializes. Accordingly, the vast majority of the absent...more

District Court Grants More Than $17,000 in Damages and Attorney’s Fees to Plaintiff Who Obtained Default Judgment in FCRA Action

Judge James Teilborg of the U.S. District Court Judge for the District of Arizona awarded Thomas McDermott over $17,000 in damages and attorney’s fees after he obtained a default judgment against collection agency, Perfection...more

Compelling Arbitration: The Eleventh Circuit Court of Appeals Reverses and Remands a District Court Holding Denying Defendant’s...

In Hearn v. Comcast Cable Communications, LLC, the Eleventh Circuit Court of Appeals reversed a district court holding denying the defendant’s motion to compel arbitration regarding the plaintiff’s Fair Credit Reporting Act...more

Second Circuit Holds Reporting a Judgment as “Satisfied” was Accurate and Provides Guidance on Defending Claims for Willfully...

The Second Circuit Court of Appeals recently upheld a ruling that reporting a judgment as “satisfied” was accurate under the Fair Credit Reporting Act (FCRA) when the underlying lawsuit was dismissed by stipulation as...more

CFPB Rescinds Guidance Regarding FCRA and Regulation V Compliance Under CARES Act

On March 31, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it is rescinding its April 1, 2020 policy statement regarding the Fair Credit Reporting Act (FCRA) and Regulation V following the enactment of...more

Supreme Court Considers Standing and Typicality for No-Injury Class Actions in TransUnion v. Ramirez Oral Argument

The U.S. Supreme Court heard oral argument yesterday in TransUnion LLC v. Ramirez, a case in which the Supreme Court is once again grappling with the requirements of Article III standing — this time in the context of class...more

Congress Considers Amendment to the FCRA to Exclude Paid Medical Debts from Credit Reports

On March 11, U.S. Representative Patrick McHenry (R-NC) reintroduced a bill to amend the Fair Credit Reporting Act (FCRA). H.R. 1645, the Protecting Consumer Access to Credit Act, would remove from a consumer’s credit report...more

California Federal Magistrate Judge Approves $175,000 Class Action Settlement for Employer’s Alleged Violation of FCRA’s...

A federal magistrate judge in the Northern District of California approved a class settlement of nearly $175,000 for an alleged violation of the FCRA’s stand-alone disclosure requirement. The class was comprised of over 1,000...more

2020 Consumer Financial Services Year in Review & A Look Ahead

2020 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Pepper is uniquely positioned to help its clients find successful resolutions...more

Ten Key FCRA Decisions of 2020

The year 2020 was an unprecedented year, but one thing remained constant: the number of Fair Credit Reporting Act (FCRA) case filings continued to increase dramatically. In addition to new filings, the year saw several key...more

Factually v. Legally Inaccurate Information, The Difference Matters: Court Rejects FCRA Claims Based on Disputed Legal Issue

On January 21, 2021, the United States District Court for the Northern District of Illinois granted TransUnion Data Solutions LLC’s (Trans Union) motion for judgment on the pleadings, denying Blue Sobenes’ (Sobenes) claims...more

Federal Preemption Does Not Always Constitute Grounds For Removal: Court Rejects Removal Based On FCRA And FDCPA Preemption Claims

On January 20, 2021, the Southern District of New York granted Emmanuel Torres’ (“Torres”) motion to remand to state court, holding that Wakefield & Associates’ (“Wakefield”) and Rural Metro Ambulance Corporation’s (“Rural...more

Home Security Company Will Pay $600,000 Civil Penalty in FCRA Settlement for Failing to Provide Risk-Based Pricing Notice

The Consumer Financial Protection Bureau (“CFPB”) has sounded the alarm on a home security company’s alleged violation of the Fair Credit Reporting Act (“FCRA”). On December 11, 2020, the CFPB announced that it and the...more

Big News for Background Screening: New Appellate Ruling Says FCRA Permits Reporting Unmatched Criminal Records

Addressing a recurring issue bedeviling the background screening industry, the U.S. Court of Appeals for the Eleventh Circuit confirmed on December 4 that it is not inaccurate for a consumer reporting agency (CRA) to report a...more

Supreme Court to Take a Stand on Standing, Granting Cert. of 9th Circuit’s Ramirez Decision

The Supreme Court granted cert in Ramirez v. TransUnion LLC to consider “whether either Article III or Rule 23 permits a damages class action where the vast majority of the class suffered no actual injury, let alone an injury...more

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