Chapter 9: Financial Privacy
Users and Furnishers Under the FCRA
Beyond CRAs, the FCRA binds users (lenders, insurers, employers who use reports) and furnishers (lenders, retailers who supply data to CRAs). Users need a permissible purpose, must certify it, and must give adverse-action notices; furnishers must provide accurate data and handle disputes.
| Role | Who | Core duties |
|---|---|---|
| CRA | Experian, Equifax, TransUnion, smaller bureaus | Provide access/dispute, ensure maximum possible accuracy, drop outdated negatives, furnish only for permissible purpose |
| User | Lenders, insurers, employers | Have and certify a permissible purpose; give adverse-action notice |
| Furnisher | Lenders, retailers | Provide accurate info, correct/update, give notice of dispute, respond to identity-theft info |
Memory hook
CRA sells the report, the user uses it, the furnisher feeds data into it. Each has distinct FCRA duties.
Companies that extend credit, even without using reports to decide, must also run a Red Flags Rule program to detect and deter identity theft.
Key terms - quick answers
What is “User”?
An entity such as a lender, insurer or employer that uses a consumer report; must have and certify a permissible purpose and provide adverse-action notice.
What is “Furnisher”?
An entity such as a lender or retailer that supplies credit history or other personal information to CRAs; must provide accurate data and respond to disputes.