CFPB issues advisory opinion on FCRA and permissible purpose

July 13, 2022 by Keith Schostag, NAFCU Compliance Blog

As NAFCU reported last week, on July 7^th the CFPB published an advisory opinion regarding “Fair Credit Reporting; Permissible Purposes for Furnishing, Using, and Obtaining Consumer Reports.” The CFPB also released this press release about the advisory opinion. While much of the focus of the advisory opinion is on credit reporting agencies (CRAs), the advisory opinion does discuss requirements for entities that obtain and use credit reports. The advisory opinion reminds users of reports that they must have a permissible purpose to obtain and use a consumer report.

Section 604(f) of the FCRA states that:

“A person shall not use or obtain a consumer report for any purpose unless

(1) the consumer report is obtained for a purpose for which the consumer report is authorized to be furnished under this section; and