On March 17, 2023, the Consumer Financial Protection Bureau (CFPB) published an updated version of the publication entitled, "A Summary of Your Rights Under the Fair Credit Reporting Act," which is also called the "Summary of Consumer Rights." This version will replace the version published in October 2018. The English and Spanish versions of the Summary and are available on the CFPB's website. Employers and consumer reporting agencies (CRAs) must provide the Summary to applicants and employees to comply with the federal Fair Credit Reporting Act (FCRA).1 Employers, for example, must include the Summary with every pre-adverse action notice.
The CFPB's changes to the Summary include non-substantive revisions to correct contact information for various federal agencies. The CFPB also revised the Summary to update references to obsolete business types, such as "Federal Land Banks," and to make other technical corrections.
Employers and CRAs should ensure they update their forms by the March 20, 2024 deadline. But employers and CRAs may want to defer implementing the updated Summary to see if the CFPB corrects at least one remaining typo. Otherwise, it might be necessary to make the same change twice if the CFPB releases a further revised version.
Footnotes
1 See, e.g., 15 U.S.C. §§ 1681g(c)(2)(A), 1681b(b)(2), 1681b(b)(3).
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