The Fourth Circuit held Plaintiff’s state debt collection statute and UDAP claims were preempted by FCRA to the extent that they were based on a furnisher’s reporting of inaccurate information to credit reporting agencies. Ross v. FDIC, 2010 WL 4261819 (4th Cir. Oct. 29, 2010). Plaintiff pled the defendant furnisher acted with malice, potentially bringing the claims within the preemption exemption in 15 U.S.C. § 1681h(e). The court declined to decide whether the federal or state law definition of malice applied, but found that under either standard, supplying information the furnisher knows is false satisfies the malice requirement. Absent proof of knowledge by the furnisher Washington Mutual, the court affirmed judgment in favor of the FDIC as Receiver.