What implications does the Fair Credit Reporting Act (FCRA) have on FinCrime and FinCrime Participants?
The FCRA contains certain exclusions from the definition of “consumer report.” One such exclusion is any report containing information solely as to transactions or experiences between the consumer and the person making the report. Under that exclusion, information published by a member of FinCrime that relates solely to the transactions or experiences between the consumer and the person making the report would not be a consumer report within the meaning of FCRA, and such a report will not violate FCRA. Accordingly, members of FinCrime should limit the information published to specific experiences between the consumer and the financial institution publishing the information on FinCrime.