Table of Contents:

I. INTRODUCTION 1; II. BACKGROUND FOR THE FTC STAFF REPORT 2; III. SUMMARY OF FCRA OBLIGATIONS ON EMPLOYERS THAT USE CONSUMER REPORTS FOR EMPLOYMENT PURPOSES 2; IV. SUMMARY OF FCRA REMEDIES 4; V. THE FTC STAFF REPORT HIGHLIGHTS OBLIGATIONS UNDER THE FCRA FOR EMPLOYERS THAT USE CONSUMER REPORTS AND INVESTIGATIVE CONSUMER REPORTS FOR EMPLOYMENT PURPOSES 5; VI. SECTION 604(B)(2): DISCLOSURES AND AUTHORIZATIONS FOR CONSUMER REPORTS AND INVESTIGATIVE CONSUMER REPORTS 7; VII. SECTIONS 604(B)(3) AND 615: THE “PRE-ADVERSE ACTION” AND “ADVERSE ACTION” NOTICES 9; VIII. CONCLUSION 10; IX. APPENDIX A — RELEVANT PORTIONS OF SECTION 604 OF THE FCRA 11; AND, APPENDIX B — FTC “A SUMMARY OF YOUR RIGHTS UNDER THE FAIR CREDIT REPORTING ACT” 13.