Yesterday, the FTC announced a settlement with Credit Bureau Collection Services (“CBCS”) and its two principals for alleged violations of the data furnisher provisions of the federal Fair Credit Reporting Act. Because CBCS is a third-party debt collector subject to the Fair Debt Collection Practices Act, the FTC included follow-on FDCPA claims covering the same subject matter as the FCRA claims.

By our count, this is only the fourth case that the FTC has brought against a data furnisher since the furnisher provisions were added to the FCRA in 1997. Moreover, this is the first case in which the FTC has elucidated in detail what it believes a furnisher is required to do when investigating information that has been disputed by a consumer.

ALLEGED VIOLATIONS

The FTC alleged that CBCS...