On June 11, 2024, the Consumer Financial Protection Bureau (CFPB) published a Notice of Proposed Rulemaking (NPRM) to amend Regulation V‒ which implements the Fair Credit Reporting Act (FCRA) ‒ limiting the inclusion of medical bills in consumer financial reports. This amendment, while providing significant benefits to Americans suffering significant medical debts, also may alter
Susan M. Corcoran
Online Public Records Aggregators Not Protected from FCRA Suit by Section 230
By Susan M. Corcoran & Kevin D. Holden on
Posted in Background Checks, Uncategorized
In a recent opinion, Henderson v. The Source for Public Data, L.P., et al, the U.S. Court of Appeals for the 4th Circuit considered whether Section 230(c)(1) of the Communications Decency Act (CDA) – a federal law that allows social media websites to provide a forum for users to post videos or other information…
Understanding CFPB’s Legal Advisory on “Permissible” Purpose
Posted in Consumer Privacy
The Consumer Financial Protection Bureau (CFPB) recently issued a legal Advisory in early July 2022, intending to protect the privacy rights of individuals subject to background checks by third-party consumer reporting agencies (CRAs) under the federal Fair Credit Reporting Act (FCRA). The Advisory also seeks to remind users (e.g., employers) of their obligations under FCRA.…