Background screening reports and the FCRA: Just saying you're not a consumer reporting agency isn't enough
You know that phrase “If it quacks like a duck. . . “? It’s applicable in the Fair Credit Reporting Act context, too. If a company meets the legal definition of a “consumer reporting agency,” it’s a consumer reporting agency. Including a disclaimer that says, in effect, “But we’re not a CRA!” won’t change that. That’s one important takeaway tip from the FTC’s settlement with Filiquarian Publishing, the agency’s first FCRA case involving mobile...