The FCRA: It’s Not Just For Credit Bureaus. Privacy Academy 2008 Orlando, Florida. Rebecca E. KUEHN Assistant Director Federal Trade Commission. Jennifer R. Rossi consumer financial services Litigator Robinson & Cole LLP. Overview.
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Privacy Academy 2008
Regardless of how you describe your business, it’s likely you use and access consumer reports.
The FCRA and FACT Act cover a wide range of activities related to accessing, collecting and using consumer information.
We will discuss what business practices are regulated by these statutes and recent FTC rules concerning identity theft.
The overall goal of this presentation is heightened appreciation for the effects of noncompliance.
We will end with a question andanswer session.
An adventure in definitions
Evolution of the information industry: A case study
Special Reports: Special Rules
What they are and what they’re not.
Are you a financial institution or creditor?
15 U.S.C. § 1681a(t) (emphasis added)
12 USCS § 461(b)(1)(C) (also known as section 19(b) of the Federal Reserve Act)
See 15 U.S.C. § 1681a(r)(5)
A “creditor” is:
15 U.S.C. §1691a(e) (also known as the Equal Credit Opportunity Act, Definitions)
(FTC Chairman, Deborah Platt Majoras, March 27, 2008)
Traps for the Unwary
Did we cover all of your questions, and/or generate new ones?
Rebecca E. Kuehn
Division of Privacy and Identity Protection
Federal Trade Commission
600 Pennsylvania Ave., N.W., NJ-3158
Washington, D.C. 20580
Jennifer R. Rossi
Consumer Financial Services Team Leader
Robinson & Cole LLP
280 Trumbull Street
Hartford, CT 06103-3597
Fair Credit Reporting Act
FTC Fair Credit Reporting Act Page
FTC Business Alert: New ‘Red Flag’ Requirements for Financial Institutions and Creditors Will Help Fight Identity Theft
Any additional questions please ask.