Fair Credit Reporting Act Update-2012

摘要

As reported in last year's Annual Survey, the Consumer Financial Protection Act of 2010 ("CFPA") revised, the Fair Credit Reporting Act ("FCRA") enforcement and rulemaking scheme, and the various federal financial regulatory agencies, including the Bureau of Consumer Financial Protection ("CFPB") and the Federal Trade Commission ("FTC"), are implementing their duties under the CFPA and FCRA. In 2012, the CFPB continued to implement its many responsibilities under the CFPA, including issuance of a rule for the supervision of "larger participants" in the consumer reporting market, while the FTC appeared to return to "business as usual," issuing an influential report urging new privacy legislation and voluntary codes of conduct for companies that collect and use consumer information. In addition to summarizing these regulatory developments, this survey examines selected FCRA litigation.