News & Analysis as of

Fair Credit Reporting Act (FCRA) Identity Theft

Goodwin

CFPB Reports on Consumer Complaint Trends

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The Consumer Financial Protection Bureau (CFPB) recently issued its annual report analyzing the consumer complaints it received in 2024.  The CFPB collects complaints through its website, phone calls, and mail....more

Troutman Pepper Locke

The Next FCRA Frontier: Identity Theft and CFPB Updates — FCRA Focus Podcast

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In this episode of FCRA Focus, hosts Kim Phan and Dave Gettings bring you the latest updates from the regulatory and litigation sides of the house. Dave shares his insights on the challenges and litigation surrounding...more

Sheppard Mullin Richter & Hampton LLP

CFPB Extends Comment Periods for Two Proposed Regulation V Rules

The CFPB is extending the comment periods for two proposed rulemakings under Regulation V, which implements the Fair Credit Reporting Act (FCRA). On March 5, the Bureau extended the comment period for its proposed rule on...more

Orrick, Herrington & Sutcliffe LLP

CFPB extends comment period on potential Regulation V amendments

On March 7, the CFPB announced a comment period extension for its advance NPRM addressing concerns related to information about coerced debt (i.e., where individuals are manipulated into incurring debt without their consent)...more

Troutman Pepper Locke

CFPB Updates List of Consumer Reporting Companies for 2025

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On January 30, the Consumer Financial Protection Bureau (CFPB or Bureau) released its updated list of consumer reporting companies for 2025. The list includes nationwide consumer reporting companies as well as several other...more

Orrick, Herrington & Sutcliffe LLP

CFPB fines credit reporting agency $15M for alleged violations

On January 17, the CFPB issued a consent order settling allegations that a consumer reporting agency (CRA) violated the FCRA and engaged in unfair acts and practices, violating the CFPA. The CFPB imposed a $15 million civil...more

Alston & Bird

CFPB Proposes to Include Coerced Debt in the Definition of “Identity Theft”

Alston & Bird on

What Happened? On December 9, the Consumer Financial Protection Bureau (“CFPB”) issued an advance notice of proposed rulemaking(“ANPR”), seeking stakeholder input regarding amending the definitions of “identity theft” and...more

Cozen O'Connor

Technology and Data at the Forefront of 2024 NAAG Capital Forum

Cozen O'Connor on

Between December 9 and 11, 2024, the National Association of Attorneys General (NAAG) held its annual Capital Forum in Washington, D.C. State AGs, AGs-elect, AG office staff, and private sector attendees heard from federal...more

Wiley Rein LLP

Wiley Consumer Protection Download (April 16, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Ballard Spahr LLP

CFPB Spring 2024 Supervisory Highlights looks at consumer reporting companies and furnishers

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The CFPB has released the Spring 2024 edition of Supervisory Highlights.  The report discusses CFPB examinations in connection with credit reporting and furnishing that were completed from April 1, 2023 through December 31,...more

Troutman Pepper Locke

Florida Federal District Court Grants Debt Collector’s Motion for Summary Judgment Citing Lack of Evidence of Inadequate FCRA...

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A U.S. District Court in the Southern District of Florida recently granted a motion for summary judgment filed by debt collector, I.C. Systems, finding that the plaintiff failed to provide any evidence of an inadequate...more

Troutman Pepper Locke

New York Federal District Court Holds the Reasonableness of Investigation Into Alleged Identity Theft is a Factual Question under...

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A U.S. district court in the Eastern District of New York recently denied a motion for summary judgment filed by a credit card issuer because the plaintiff alleged identity theft and a reasonable factfinder could determine...more

Troutman Pepper Locke

The 7 Most Notable FCRA Cases of 2023 So Far

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The first half of 2023 has produced significant developments for the Fair Credit Reporting Act. Important decisions have come from multiple areas of the field, including the federal courts of appeals and regulatory agencies. ...more

Troutman Pepper Locke

Wisconsin Federal District Court Denies Cross-Motions for Summary Judgment Holding the Reasonableness of Furnisher’s Investigation...

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A U.S. District Court in the Western District of Wisconsin recently denied both the defendant and plaintiff’s summary judgment motions in a Fair Credit Reporting Act (FCRA) case, holding that the reasonableness of the...more

Rosenberg Martin Greenberg LLP

Third Circuit Holds That Furnisher Who Receives Notice of an Indirect Dispute Has Absolute Duty to Investigate Under FCRA

News accounts of instances of stolen identity in which identity thieves incur debts in the names of innocent consumers are common. Given the structure of the consumer credit industry, it is difficult for consumers to know...more

Ballard Spahr LLP

FTC and CFPB submit amicus brief in Second Circuit on FCRA requirement for furnisher to conduct reasonable investigation of...

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The Federal Trade Commission (“FTC”) and the Consumer Financial Protection Bureau (“CFPB”) have filed a joint amicus brief in which they urge the U.S. Court of Appeals for the Second Circuit to reverse the decision of a New...more

Balch & Bingham LLP

Third Circuit Holds Creditors Should Investigate All Indirect Disputes Of Accounts On A Credit Report - (Video Transcript)

Balch & Bingham LLP on

Welcome to Balch's Consumer Finance Compass, where we'll navigate the complex regulatory sphere that is consumer finance. I'm Jason Tompkins, chair of the firm's Issues and Appeals Practice and member of the Consumer Finance...more

Troutman Pepper Locke

CFPB and FTC File Amicus Brief Urging Second Circuit to Find FCRA Requires Unverified Information to be Deleted from Consumer...

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Recently, the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) (collectively, the agencies) filed an amici curiae brief urging the U.S. Court of Appeals for the Second Circuit to reverse a...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Responding to Direct and Indirect Identity Theft Disputes Under the FCRA: What Are The...

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We first review the Fair Credit Reporting Act provisions that establish the different requirements for how a creditor or other furnisher of information to a credit bureau must respond to direct and indirect identify theft...more

Burr & Forman

Eleventh Circuit Confirms Investigation into Dispute Involving Identity Theft Was Reasonable and Affirms Summary Judgment on FCRA...

Burr & Forman on

In Milgram v. Chase Bank USA, N.A., --- F.4th ---, 2023 WL 3874276 (11th Cir. June 8, 2023), the Eleventh Circuit affirmed the district court’s dismissal of plaintiff’s FCRA claim based on the bank’s alleged failure to...more

Troutman Pepper Locke

Federal District Court Grants Summary Judgment Dismissing Claim that Creditor Conducted an Unreasonable Investigation of a FCRA...

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In Suluki v. Credit One Bank, N.A. (Credit One), the Southern District of New York recently granted summary judgement to a creditor in a suit alleging violations of the Fair Credit Reporting Act (FCRA) for failure to conduct...more

Lowenstein Sandler LLP

SEC Releases Risk Alert Regarding Compliance Issues With Identity Theft Prevention Programs Under Regulation S-ID

Lowenstein Sandler LLP on

On December 5, 2022, the Division of Examinations (EXAMS) of the Securities and Exchange Commission (SEC) issued a Risk Alert regarding recently observed compliance issues with respect to Regulation S-ID. Under Regulation...more

Burr & Forman

Seventh Circuit Affirms Dismissal of FDCPA and FCRA Claims Arising from Identity Theft

Burr & Forman on

In Woods v. LVNV Funding, LLC, — F. 4th — (2022), the Seventh Circuit Court of Appeals affirmed the dismissal of FDCPA and FCRA claims based upon the defendants’ collection and reporting of a fraudulently opened account....more

Sheppard Mullin Richter & Hampton LLP

FTC 2022 Regulatory Priorities to Include Privacy and Security

As we look to 2022, a question on many companies’ minds is what actions we will see from the FTC. Two recent developments are important on that front. First, the FTC recently signaled its intent to initiate rulemaking on...more

Burr & Forman

Investigating and Defending Identity Theft Claims Against Furnishers Under The Fair Credit Reporting Act

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Introduction - The Fair Credit Reporting Act (FCRA) was enacted to promote the accuracy, fairness, and privacy of information maintained by Consumer Reporting Agencies (CRAs). In addition to imposing duties on the CRAs,...more

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