In the July 12, 2022, issue of the Federal Register (87 FR 41243) the CFPB published the above Advisory Opinion (the “Opinion”) to “outline certain obligations of consumer reporting agencies and consumer report users under section 604 [15 U.S.C. §1681b] of the Fair Credit Reporting Act (FCRA).” The Opinion is effective as of July 12, 2022.
The below quotations from the Advisory Opinion summarize what we consider are its major points:
“[T]he permissible purposes identified in FCRA section 604(a)(3) [for furnishing a consumer report] are consumer specific [that is, they apply only with respect to the consumer who is the subject of the user’s request], and it affirms that a consumer reporting agency may not provide a consumer report to a user under FCRA section 604(a)(3) unless it has reason to believe that all the consumer report information it includes pertains to the consumer who is the subject of the user’s request.”
Full Memorandum
