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1.3.3.2.4 FTC and CFPB studies

In addition to the Staff Summary and informal staff opinions, the FTC has issued a number of reports and studies on credit reporting issues.120 Since 2011, the CFPB has issued a number of such studies as well.121 Such reports do not constitute binding authority, in that they are not a statutory interpretation, rulemaking, or other agency action to which a court must give deference.122

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