News & Analysis as of

Credit Reporting Agencies

Troutman Pepper Locke

October 2025 Consumer Litigation Filings: Another Mixed Bag, But Up Over 2024

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According to a recent report by WebRecon, court filings under the Fair Debt Collection Practices Act (FDCPA) and Fair Credit Reporting Act (FCRA) rose by double digits while litigation under Telephone Consumer Protection Act...more

Ballard Spahr LLP

ACA Files Suit Challenging Colorado Law That Omits Medical Debts From Credit Reports

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The trade group representing debt collection agencies, creditors, debt buyers, collection attorneys, and debt collection industry service providers has filed suit challenging the Colorado law that bans the inclusion of...more

A&O Shearman

UK FCA Statement On Credit Builder Products

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The UK Financial Conduct Authority (FCA) has published a statement with findings from its review of certain credit builder products, which claim to improve consumers' credit scores by reporting regular payments to credit...more

Orrick, Herrington & Sutcliffe LLP

District court allows CFPB’s amended FCRA claims to proceed against credit reporting agency

On October 22, the U.S. District Court for the Central District of California denied a credit reporting agency’s renewed partial motion to dismiss and motion to strike the CFPB’s second amended complaint in ongoing litigation...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Medical Debt in Credit Reports: What Employers Need to Know Amid Legal Shifts

With health care costs rising, recent legal developments have altered how medical debt shows up on credit reports that employers conduct on job applicants and employees. Employers may want to stay abreast of the changing...more

Sheppard Mullin Richter & Hampton LLP

Colorado’s Medical Debt Reporting Law Challenged in Federal Court

On November 5, 2025, a national debt collection trade group and one of its members filed a lawsuit against the state of Colorado’s in an attempt to block its 2023 medical debt credit reporting law, HB 23-1126. The complaint...more

DLA Piper

Dutch DPA fines Experian €2.7m for breaches of the GDPR

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The Dutch Data Protection Authority (“AP“) has imposed a fine of €2.7 million on Experian Nederland B.V. (“Experian“) for breaches the General Data Protection Regulation (“GDPR“)....more

Hogan Lovells

Financial Inclusion: UK government’s Strategy looks to embed accessibility and support into products and services

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Financial inclusion remains a particular area of focus for both the FCA and the government, and on 5 November 2025 HM Treasury (HMT) published its awaited Financial Inclusion Strategy....more

Orrick, Herrington & Sutcliffe LLP

CFPB withdraws FCRA interpretive rule and clarifies state preemption

On October 28, the CFPB published an interpretive rule in the Federal Register, replacing a previously withdrawn 2022 FCRA interpretive rule and clarifying that the FCRA “generally preempts State laws that touch on broad...more

Orrick, Herrington & Sutcliffe LLP

Kansas district court finds extra efforts and expenses sufficient for standing in FDCPA suit

On October 16, a judge in the U.S. District Court for the District of Kansas denied a defendant’s motion to dismiss an FDCPA case, holding that the plaintiff had standing to pursue her claims. ...more

Sheppard Mullin Richter & Hampton LLP

Maryland OFR Issues Guidance on New Medical Debt Collection Laws

On October 14, the Maryland Office of Financial Regulation (OFR) issued regulatory guidance explaining three new state laws governing the collection and reporting of medical debt. The guidance clarifies how House Bills 428,...more

Jackson Lewis P.C.

Credit Checks in Hiring: Key Issues for Financial Services Employers After Medical Debt Reporting Restrictions

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Evolving credit checks requirements means employers in financial services are challenged more than ever to stay current because they conduct credit checks on prospective candidates more frequently than those in many other...more

Orrick, Herrington & Sutcliffe LLP

FTC announces $5.7M settlement to resolve prior violations by credit report provider

On September 29, the FTC announced a $5.7 million proposed settlement with a business credit report provider to resolve allegations that it violated a 2022 FTC order. ...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks to revive credit reporting suit after dismissal on statute of limitations grounds

On September 26, the CFPB filed a memorandum opposing a credit reporting agency’s renewed motion to dismiss the Bureau’s second amended complaint in ongoing litigation in the U.S. District Court for the Central District of...more

A&O Shearman

HMT Consultation and Call for Evidence on Commercial Data Sharing

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HM Treasury (HMT) has launched a consultation and call for evidence to assess potential enhancements to the UK's Commercial Credit Data Sharing (CCDS) scheme. CCDS, established under the Small and Medium Sized Business...more

Hudson Cook, LLP

FTC Announced Settlement with Business Credit Report Service Provider over Violations of Previous FTC Order

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In a new consent order with the FTC, the Company has agreed to pay $5.7 million to resolve allegations that it violated a 2022 FTC order finding that it engaged in unfair and deceptive practices by providing inaccurate...more

Bradley Arant Boult Cummings LLP

California Enacts Mortgage Forbearance Act, Effective Immediately; Will Pose Compliance Challenges for Servicers

On September 22, 2025, California Gov. Gavin Newsom signed the Mortgage Forbearance Act into law, with an immediate effective date. The law, designed to provide emergency relief to California mortgage loan borrowers impacted...more

Cozen O'Connor

Democratic AGs Urge CFPB to Maintain Oversight of Risky Markets

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A group of 19 Democratic AGs sent letters to the CFPB opposing proposals that would narrow the Bureau’s oversight in certain markets and reduce the number of companies subject to regulation. In their letters regarding...more

Ballard Spahr LLP

CFPB Spring 2025 Regulatory Agenda – Prerule Stage – Identity Theft and Coerced Debt (Regulation V)

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The CFPB is considering proposing amendments to Regulation V, which implements the Fair Credit Reporting Act (FCRA), to address concerns related to information furnished to consumer reporting agencies regarding coerced debt. ...more

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #460 – Protecting Foster Youth from Identity Theft

I served on the Board, and am a big fan of Foster Forward, an amazing organization located in Rhode Island that provides services to foster children and youth and supports the child welfare system as a whole. During my many...more

Sheppard Mullin Richter & Hampton LLP

Homebuyers Privacy Protection Act Signed Into Law, Restricting Trigger Leads

On September 5, the Homebuyers Privacy Protection Act (H.R. 2808) was signed into law. The law amends the Fair Credit Reporting Act to restrict the sale of consumer information generated when borrowers apply for residential...more

A&O Shearman

IWG Response to FCA Feedback on Its Final Report on Credit Information Market Study

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The Interim Working Group (IWG) advising on the UK Financial Conduct Authority's (FCA) Credit Information Market Study has issued a formal response to the FCA's feedback on its final report regarding the establishment of the...more

Holland & Knight LLP

New Jersey Financial Services Legislative Update

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This alert is part of Holland & Knight's Garden State Initiative, a firmwide effort to enhance coordination among attorneys, clients and professional networks with ties to New Jersey to foster greater collaboration across...more

BCLP

Eleventh Circuit Weeds Out Plaintiffs Who “Manufacture” Article III Standing With Self-Inflicted Harm

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On July 18, 2025, the Eleventh Circuit rejected the notion that plaintiffs can “manufacture” Article III standing by identifying “self-inflicted harm” such as “expenditure of money and wasted time to correct an otherwise...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes four ANPRs seeking comment on the definitions of “larger participants” in specific supervised industries

On August 8, the CFPB published four advance notices of proposed rulemaking in the Federal Register seeking public comment to reconsider the test for defining larger participants in the consumer reporting, debt collection,...more

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