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CFPB Files Lawsuit Against SoLo Funds for Alleged Deceptive Lending Practices

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a complaint against SoLo Funds, Inc., a fintech company operating a small-dollar, short-term lending platform. The CFPB alleges that SoLo Funds...more

Eleventh Circuit Declines to Issue Brightline Rule that Legal Disputes are Not Actionable Under FCRA Instead Finding That Disputes...

In Holden v. Holiday Inn Club Vacations Inc., the U.S. Court of Appeals for the Eleventh Circuit recently upheld a consolidated district court ruling granting summary judgment for the defendant furnisher in two Fair Credit...more

Ninth Circuit Affirms Summary Judgment Finding that Furnisher Conducted a Reasonable Investigation into Dispute

In an unpublished decision, the U.S. Court of Appeals for the Ninth Circuit recently affirmed the decision of a California district court finding that the furnisher conducted a reasonable investigation under the Fair Credit...more

CFPB’s Spring Edition of Its Supervisory Highlights Focuses on Consumer Reporting

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) released the spring edition of its Supervisory Highlights report, providing a high-level overview of alleged unfair, deceptive, or abusive acts or practices...more

New York Federal Court Finds Failure to Review Account Notes When Investigating a Dispute Could Be Considered Reckless Under the...

In Martinez v. Celtic Bank, the Southern District of New York recently denied a motion for summary judgment finding that a jury could consider an investigation reckless when a furnisher fails to review any records other than...more

New York Federal District Court Holds the Reasonableness of Investigation Into Alleged Identity Theft is a Factual Question under...

A U.S. district court in the Eastern District of New York recently denied a motion for summary judgment filed by a credit card issuer because the plaintiff alleged identity theft and a reasonable factfinder could determine...more

Kentucky Introduces Legislation Requiring CRAs to Obtain Express Consumer Consent Prior to Furnishing a Consumer Report or Credit...

On February 16, Kentucky state representative Steve Bratcher (R) introduced House Bill (HB) 578. The bill seeks to create a new section of the Kentucky Consumer Protection Act that would restrict how consumer reporting...more

Supreme Court Holds Government Agencies are Not Immune from FCRA Liability

On February 8, the U.S. Supreme Court issued a unanimous decision in Department of Agriculture Rural Development Rural Housing Service (USDA) v. Kirtz, holding that the Fair Credit Reporting Act’s (FCRA) clear statutory text...more

Nevada Federal Court Declines to Decide at Summary Judgment Stage Whether Pre-Dispute Investigation Was Sufficient to Satisfy FCRA

A federal district court judge in Nevada recently denied competing motions for summary judgment in a Fair Credit Reporting Act (FCRA) furnisher investigation case, demonstrating the challenges FCRA litigants often face in...more

FTC's Sensitive Location Privacy Collection and Sale Expectations: Insights From Data Broker Settlements (and 10 Action Items to...

Following several years of investigating the common practices in the space, the Federal Trade Commission (FTC) reached its first settlement with a data broker over the alleged collection and sale of location information that...more

CFPB Continues Focus on Consumer Reporting and the FCRA With New “Guidance” on Background Checks and Consumer Disclosures

On January 11, the Consumer Financial Protection Bureau (CFPB or Bureau) issued two “advisory opinions” addressing the CFPB’s views of the obligations of consumer reporting agencies (CRAs) under the Fair Credit Reporting Act...more

Magistrate Judge Recommends No FCRA Liability for Accurately Reporting a Publicly Available Conviction that was Expunged

A magistrate judge in the Northern District of Georgia recently recommended granting summary judgment in a Fair Credit Reporting Act (FCRA) case in favor of a background reporting company on the grounds that a report given...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - January 2024

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

CFPB and FTC File Amicus Brief Urging Fourth Circuit to Find FCRA Requires Investigation Regardless of Whether Dispute Is Factual...

On December 8, the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) (collectively, the agencies) filed an amici curiae brief urging the U.S. Court of Appeals for the Fourth Circuit to reverse a...more

New York Bans Reporting of Medical Debt Effective Immediately

On December 13, New York Governor Kathy Hochul signed into law S4907A, which prohibits hospitals, medical providers, or ambulance services from providing negative information about medical debt to consumer reporting agencies...more

Federal Magistrate Recommends Dismissal of FDCPA and FCRA Case on Statute of Limitation and Reasonableness of Reporting Grounds

On November 9, a magistrate judge in the Northern District of Georgia issued a Report & Recommendation to grant a motion to dismiss because the plaintiff’s Fair Debt Collection Practices Act (FDCPA) claims were time-barred...more

Wisconsin Federal District Court Denies Cross-Motions for Summary Judgment Holding the Reasonableness of Furnisher’s Investigation...

A U.S. District Court in the Western District of Wisconsin recently denied both the defendant and plaintiff’s summary judgment motions in a Fair Credit Reporting Act (FCRA) case, holding that the reasonableness of the...more

A Tale of Two Credit Scores: Illinois Federal Court Denies Class Certification Of "Misleading" Credit Score Case

On October 12, the U.S. District Court for the Northern District of Illinois denied certification of a putative class action asserting that TransUnion violated the Fair Credit Reporting Act (FCRA) and the Missouri...more

Third Circuit Finds No Exception Under FCRA for a Furnisher’s Failure to Investigate “Frivolous” Indirect Dispute

The Third Circuit Court of Appeals overruled a district court’s reading of an exception into §1681s-2(b) of the Fair Credit Reporting Act (FCRA) that would allow a furnisher discretion to refuse to investigate an indirect...more

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