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Re: Proposed Fcra Interpretations

By Chanin, Leonard N.

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Book Id: WPLBN0000050575
Format Type: PDF eBook
File Size: 3.8 MB
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Title: Re: Proposed Fcra Interpretations  
Author: Chanin, Leonard N.
Language: English
Subject: Trade, Import and export controls, Federal Trade Commission (U.S.)
Collections: Economics Publications Collection, Federal Trade Commission
Publication Date:
Publisher: Government Printing Office


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Chanin, L. N. (n.d.). Re: Proposed Fcra Interpretations. Retrieved from

Government Reference Publication

The FCRA provides that a consumer report does not include the communication of certain information among affiliated companies if the consumer is informed that the information may be shared and is given the opportunity to direct that such information not be shared. The supplementary information accompanying the Proposed Interpretations notes that because transaction and experience information is not a consumer report such information may be shared among affiliated parties without providing an opt out notice, and the sharing party would not be viewed as a consumer reporting agency. The FTC should clarify that many other arrangements involving the transmission of nontransaction or nonexperience information by one affiliated party to another affiliated al- so would not reauire an o outt notice. nor would such a transmission expose affiliated entities to the duties imposed on consumer reporting agencies. In particular, it is common for affiliated financial institutions to underwrite transactions &rough one of several affiliated companies. Typically, these affiliated companies use a common information technology (IT) system and a common service affiliate to evaluate applications and related information received by the institutions generally...


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