On October 21, the FTC announced a $2.95 million settlement with a telecommunications company for alleged violations of the FCRA. According to the FTC, the company violated the FCRA’s Risk-Based Pricing Rule by failing to provide consumers with a fully compliant risk-based pricing notice when they were placed into a cell phone and data service program with an additional monthly fee because of information from their consumer reports and their credit scores. Specifically, the FTC’s complaint alleges that the company (i) failed to provide consumers in the program with required disclosures in their risk-based pricing notices, such as the key factors that adversely affected their credit scores and language encouraging consumers to verify the accuracy of their consumer reports; and (ii) provided consumers with the disclosures only after they have become contractually obligated. In addition to the $2.95 million civil money penalty, the proposed consent order would require the company to (i) abide by the requirements of the Risk-Based Pricing Rule in the future; (ii) provide consumers with the proper disclosures within five days of signing up for the company’s services, or by a certain date that would allow them to avoid recurring charges; and (iii) send the consumers who originally received incomplete disclosures new, corrected risk-based pricing notices. The proposed order is subject to court approval in the District Court for the District of Kansas.