Fair Credit Reporting; File Disclosure, 89 Fed. Reg. 4167 (Jan. 23, 2024)

The Consumer Financial Protection Bureau (CFPB or Bureau) is issuing this advisory opinion to address certain obligations that consumer reporting agencies have under section 609(a) of the Fair Credit Reporting Act (FCRA). This advisory opinion underscores that, to trigger a consumer reporting agency’s file disclosure requirement under FCRA section 609(a), a consumer does not need to use specific language, such as ‘‘complete file’’ or ‘‘file.’’ This advisory opinion also highlights the requirements regarding the information that must be disclosed to a consumer under FCRA section 609(a). In addition, this advisory opinion affirms that consumer reporting agencies must disclose to a consumer both the original source and any intermediary or vendor source (or sources) that provide the item of information to the consumer reporting agency under FCRA section 609(a).