Introduction
Many companies believe that they are beyond the reach of the Fair Credit Reporting Act (FCRA) because they do not engage in typical “credit” reporting; however, such beliefs are enormous…
The First CFPB Administrative Appeal: RESPA, Kickbacks, and the Danger of De Novo Review
In Brief
- Due to its broad scope and expansive reach, the FCRA is likely regulating your client’s business.
- Besides the ever-expanding FCRA class-action arena, federal regulatory enforcement has become just as prominent, with the CFPB and FTC prosecuting FCRA violations by furnishers of consumer information.
- Common claims include a failure to maintain reasonable procedures against CRAs and adverse action notices against employers.
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