News & Analysis as of

Credit Reports

McGlinchey Stafford

Southern District of New York Finds No Private Right of Action for Improper Reporting Under the FCRA

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The Southern District of New York dismissed an action under the Fair Credit Reporting Act (FCRA), finding that there was no private right of action under section 1681s-2(a) for purportedly inaccurate reporting by a furnisher....more

Morgan Lewis

Consumer Finance in the US Automotive Industry

Morgan Lewis on

As the legal environment for consumer financial services continues to shift through 2025, regulatory activity in the automotive sector has emerged as a fast-evolving area of focus for industry stakeholders. Recent...more

Foley & Lardner LLP

Maryland Insurance Administration Proposes to Revise Regulation Governing Disclosures of Credit Scoring Use in Private Passenger...

Foley & Lardner LLP on

The Maryland Insurance Administration (MIA) recently proposed to revise a regulation regarding the use and disclosure of credit history in underwriting and rate making for personal automobile policies. Specifically, the...more

Hudson Cook, LLP

When Does a Consumer's Permission to Make Credit Inquiries Expire?

Hudson Cook, LLP on

If at first you don't succeed, try, try again, right? That advice may be good for life in general, but it's not so good for running credit inquiries. ...more

Saul Ewing LLP

Eleventh Circuit Rules “Self-Inflicted” Harm Does Not Create FCRA Standing

Saul Ewing LLP on

If an error is in a credit file and no one is around to see it, does it create standing? No, according to the U.S. Court of Appeals for the Eleventh Circuit, noting a plaintiff “cannot manufacture standing by spending time...more

Fox Rothschild LLP

Court Vacates CFPB Medical Debt Rule: Key Takeaways for Providers

Fox Rothschild LLP on

Earlier this month, the United States District Court for the Eastern District of Texas approved a consent judgment vacating the Consumer Financial Protection Bureau’s (CFPB) Medical Debt Rule. The decision holds that the CFPB...more

Brownstein Hyatt Farber Schreck

FHFA Reverses Course on Bi-Merge; Opens Door to VantageScore 4.0

In a July 8 social media post, Federal Housing Finance Agency (FHFA) Director Bill Pulte stated that Fannie Mae and Freddie Mac (the Enterprises) will maintain the long-standing tri-merge requirement requiring lenders to pull...more

A&O Shearman

FCA final report on credit information market study

A&O Shearman on

The UK Financial Conduct Authority (FCA) has published its feedback to the interim working group's final report on credit information market governance, which was developed in response to the FCA's Credit Information Market...more

Orrick, Herrington & Sutcliffe LLP

District court tosses CFPB’s medical debt rule

On July 11, the U.S. District Court for the Northern District of Texas vacated the CFPB’s medical debt rule on the grounds that it exceeded the Bureau’s statutory authority and violated both the FCRA and the APA, granting the...more

Troutman Pepper Locke

CFPB Will Not Reissue Medical Debt Advisory Opinion

Troutman Pepper Locke on

On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a status report announcing its decision not to reissue its Medical Debt Collection Advisory Opinion, which had been issued in 2024 to “remind debt...more

Ballard Spahr LLP

Federal Judge vacates CFPB medical debt rule

Ballard Spahr LLP on

A Texas federal judge has voided a Biden Administration CFPB rule that would have prohibited medical debt in credit reports....more

Sheppard Mullin Richter & Hampton LLP

Rhode Island Enacts Ban on Reporting Medical Debt to Credit Bureaus

On June 26, Rhode Island Governor Dan McKee signed companion bills S 0169 and S 0172 into law, twin measures that amend the state’s Deceptive Trade Practices Act and Interest and Usury statute to impose some of the nation’s...more

Orrick, Herrington & Sutcliffe LLP

Eleventh Circuit reverses “clickwrap” case in favor of credit agency

On July 3, the U.S. Court of Appeals for the Eleventh Circuit reversed and remanded a district court’s denial of a motion to compel arbitration, ordering that a dispute between an individual and a credit reporting company...more

Proskauer - Minding Your Business

Buy Now, Pay Later: Regulatory Retreat in Washington, State Regulation on the Rise

Each year, upwards of 100,000 music fans pay up to $599 for the ticket price of weekend-long admission to the Coachella Music and Arts festival outside of Palm Springs, California. In 2025, however, nearly 60% of Coachella’s...more

Sheppard Mullin Richter & Hampton LLP

Oregon Prohibits Medical Debt in Credit Reports

On June 23, Oregon enacted SB 605, barring medical-debt information from appearing in consumer credit reports. The measure, which amends the Oregon Unlawful Trade Practices Act, takes effect January 1, 2026....more

McGlinchey Stafford

Fifth Circuit Affirms FCRA Limits: Credit Reporting Agencies are Not Required to Resolve Fraud Claims

McGlinchey Stafford on

In a case of first impression, the Fifth Circuit in Reyes v. Equifax Information Systems, L.L.C., joined the First, Seventh, Ninth, and Tenth Circuits in affirming the District Court for the Eastern District of Texas’s...more

Troutman Pepper Locke

Insights from the CFPB’s Latest Report on Credit Invisibility

Troutman Pepper Locke on

n June 23, the Consumer Financial Protection Bureau (CFPB or Bureau) released an update to its 2015 report on Americans who did not have a credit record (credit invisibles) or who had insufficient credit history to have a...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – July 2025

Troutman Pepper Locke on

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

Hudson Cook, LLP

CFPB's Consumer Response Annual Report for 2024 Analyzes Increased Consumer Complaints

Hudson Cook, LLP on

The Consumer Financial Protection Bureau recently delivered its Consumer Response Annual Report for 2024, as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The report includes analyses of...more

Orrick, Herrington & Sutcliffe LLP

CFPB issues correction of “credit invisibles” estimate

On June 23, the CFPB issued a technical correction and update to its estimate of “credit invisibles” — adults in the U.S. without a credit record or with insufficient credit history to generate a credit score. As previously...more

Orrick, Herrington & Sutcliffe LLP

Oregon prohibits reporting medical debt to consumer reporting agencies

On June 23, the Oregon Legislature chaptered SB 605, enacting new restrictions on the reporting of medical debt to consumer reporting agencies. The law prohibits any person from reporting to a consumer reporting agency the...more

Orrick, Herrington & Sutcliffe LLP

Maine amends law to ban medical debt reporting to credit bureaus

On June 9, the governor of Maine approved LD 558, which prohibits medical creditors, debt collectors, and debt buyers from reporting consumer medical debt to consumer reporting agencies. The new law replaces previous...more

Spilman Thomas & Battle, PLLC

The Health Record - Healthcare Law Insights, V 2, Issue 6, June 2025

Welcome to our sixth issue of 2025 of The Health Record -- our healthcare law insights e-newsletter. In this edition, we look at the impact of supply chain and tariff issues on the industry, the veto of Florida's...more

Troutman Pepper Locke

Second Circuit Explains Reasonable Investigation Standard in Identity Theft Case Under FCRA

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In a recent decision, the U.S. Court of Appeals for the Second Circuit clarified the expectations for furnishers when investigating consumer disputes under the Fair Credit Reporting Act (FCRA). In Suluki v. Credit One Bank,...more

Sheppard Mullin Richter & Hampton LLP

Fourth Circuit Expands FCRA Liability: Legal Inaccuracies Now Actionable

On March 14, the U.S. Court of Appeals for the Fourth Circuit vacated the dismissal of a lawsuit alleging a failure to reasonably investigate a disputed debt. The lawsuit concerned a consumer who disputed a debt that she...more

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