The FTC and the Consumer Financial Protection Bureau (“CFPB”) officials have recently committed to maintain pressure on technology companies, telecoms and banks that collect and use large consumer data sets, based on the Fair Credit Reporting Act, the aim of which is to promote the accuracy, fairness, and privacy of information in the files of consumer reporting agencies (“CRAs”).

In order to ensure compliance, the FTC pursues an aggressive enforcement program aimed at the main players in the credit reporting system – CRAs, which send them information and consumer report users. It should be noted that in recent years, the FTC has sued the three nationwide CRAs – Equifax, Experian, and TransUnion – obtaining nearly US$3 million in civil penalties. The FTC has also sued a major consumer data broker, ChoicePoint, Inc., and required them to pay US$15 million in penalties and consumer refunds for not screening prospective subscribers before selling them sensitive consumer information.