18.104.22.168 The Appendices
Considerable attention has been given in this treatise to including significant FCRA materials in the appendices and making them available as companion material to the digital version of this treatise. Appendix A, infra, contains the FCRA in its current form. The companion material available with the digital version of this treatise includes various versions of the FCRA and the public laws that amended it:
- ● The public law version of the sections of the Dodd-Frank Act that amend the FCRA;
- ● A version of the FCRA that displays the Dodd-Frank Act amendments in redline;
- ● The FCRA prior to the Dodd-Frank Act;
- ● The public law version of the Fair and Accurate Credit Transactions Act of 2003 (FACTA);
- ● A version of the FCRA that displays the FACTA amendments in redline;
- ● The FCRA prior to FACTA; and
- ● The FCRA prior to the 1996 Reform Act.
Appendix B, infra, contains the regulations that implement the FCRA, mostly issued pursuant to the FACTA amendments. The primary regulation is Regulation V, issued by the Consumer Financial Protection Bureau (CFPB). Note that Appendix B, infra, also includes regulations issued by the Federal Trade Commission (FTC), which has authority over a few sections of the FCRA as well as automobile dealers in their role as furnishers of information. The federal banking regulators have parallel sets of FCRA regulations that were issued prior to the Dodd-Frank Act’s transfer of regulatory authority to the CFPB, and these regulations are still on the books. These regulations are not included in this treatise, but are essentially the same as the CFPB/FTC regulations. There is a table in Appendix B, infra, that sets forth the cites for parallel regulations.
Appendix C, infra, provides the model forms that the CFPB and FTC have issued concerning the FCRA, along with a copy of the adverse action notice required by the Equal Credit Opportunity Act. Appendix D, infra, contains the FTC’s Staff Summary on the FCRA. An index to the FTC’s informal staff opinion letters, organized by FCRA section, is provided in Appendix E, infra; the letters themselves are available as companion material to the digital version of this treatise.
Appendix F, infra, reproduces the Credit Repair Organizations Act. Appendix G, infra, contains the Gramm-Leach-Bliley Act, its regulations, and examples of model notices that comply with that act. Appendix H, infra, provides a state-by-state summary of state laws that affect consumer credit reports, including credit and consumer reporting statutes, identity theft statutes, credit repair organization statutes, security freeze laws, and similar legislation. Appendix I, infra, contains sample credit reports and other consumer reporting agency documents. Appendix J, infra, provides sample FCRA complaints. Appendix K, infra, provides sample settlement language to address credit reporting. Appendix L, infra, summarizes enforcement orders from government agencies against violators; the actual orders are available digitally as companion material to this treatise.
Appendix M, infra, gives guidance for understanding consumer reports and credit scores, while Appendix N, infra, lists helpful fair credit reporting websites. Appendix O, infra, includes a listing of consumer reporting agencies (CRAs) and other database companies, the latter of which may or may not be CRAs. It is a work in progress and subject to frequent change.