Compliance and its importance for employers and landlords is discussed in the news extensively, but a recent proposed judgment against a Consumer Reporting Agency (CRA) demonstrates that compliance, or lack thereof, can affect even those who should be well-versed (and practiced) in the various requirements.  The Consumer Financial Protection Bureau (Bureau) alleged that the CRA violated the Fair Credit Reporting Act (FCRA) by:

(1) failing to employ reasonable procedures to ensure the maximum possible accuracy of the information about consumers it included in the consumer reports it prepared;

(2) failing to maintain strict procedures to ensure that public record information about consumers that it included in consumer reports it prepared was complete and up to date or notify consumers, at the time that such information was reported, of the fact that public record information was being reported; and

(3) reporting criminal history information and other adverse information about consumers outside of the reporting period allowed by the FCRA.

If entered, the CRA will have to pay $6 million in relief to affected consumers and $2.5 million in penalties to the Bureau.

 

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