FCRA GETS SHARPER TEETH — CFPB's New Opinions Raise the Stakes for Data Handlers


The Consumer Financial Protection Bureau (CFPB) has released four new advisory opinions that make one thing crystal clear:


credit reporting violations just got riskier—for data furnishers, background check companies, and credit bureaus alike.


These clarifications further empower consumers to challenge inaccurate information, and they reinforce what R23 Law’s California Consumer Protection Attorneys have long argued: if your credit report is wrong, the law is on your side.

What’s New in the CFPB’s Latest Opinions?

The CFPB’s recent advisory opinions clarify and expand the enforcement power of the Fair Credit Reporting Act (FCRA)—a federal law that governs how your financial and personal data is collected, reported, and used.

Here’s what the CFPB reaffirmed:

1. Consumers Must Be Informed of Their Rights—Clearly

Background check companies and credit bureaus must provide disclosures that are “clear and conspicuous”—not hidden in legalese or buried in fine print. If your rights are not clearly explained, the company may be in violation of the FCRA.

2. “Permissible Purpose” Matters—No Fishing Allowed

Entities pulling your credit report must have a legally valid reason (a “permissible purpose”) for doing so. If a landlord, employer, or debt collector pulls your report without proper cause, it’s not just unethical—it may be a legal violation.

3. Consumers Can’t Be Forced to Waive FCRA Rights

Companies cannot trick or pressure you into waiving your legal rights under the FCRA. Even if you’ve signed something that appears to limit your rights, it likely won’t hold up in court.

4. All Report Users Must Certify Purpose—and Face Consequences if They Don’t

Companies using consumer reports must certify their intended use in writing. If they lie—or use the report for a different purpose—they could face legal consequences.

Why These Opinions Matter for Californians

California already has some of the strongest consumer protection laws in the country. But with these federal opinions, the gap between legal theory and practical enforcement just got smaller.

These new rules put pressure on:

  • Credit bureaus that continue to report outdated or inaccurate information

  • Background check companies that ignore expungements or sealed records

  • Debt collectors and landlords who pull reports without proper authorization

  • Employers who bury background check disclosures in fine print

If your consumer rights were violated, the new guidance strengthens your potential case under the FCRA—and R23 Law’s California Consumer Protection Attorneys are ready to act.

Your Rights Under the FCRA—Now Clearer Than Ever

You have a legal right to:

  • Access your credit report for free

  • Dispute inaccurate or outdated information

  • Be told if your report was used to deny you a job, loan, or apartment

  • Know exactly why your report was accessed

  • Sue for damages if your rights were violated

And with these new CFPB opinions, your rights are not just clearer—they’re more enforceable.

How R23 Law Protects Consumers Like You

At R23 Law, we specialize in fighting back when your consumer data is mishandled. Our R23 Law California Consumer Protection Attorneys can:

  • Investigate unauthorized or incorrect credit pulls

  • Dispute errors on your credit or background report

  • Take legal action against companies violating the FCRA or ICRAA

  • Secure financial compensation for harms caused by false data

Whether you’ve lost a job, housing opportunity, or peace of mind—you may be entitled to damages.

Take Action If Your Rights Have Been Violated

The CFPB has thrown down the gauntlet. If your consumer report was accessed, used, or shared illegally, now is the time to act.

📞 Contact R23 Law’s California Consumer Protection Attorneys for a free consultation. We offer services in multiple languages and represent clients statewide.

Your information is yours. Let us make sure it stays that way.

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EXPUNGED ≠ ERASED — When Background Check Errors Keep Haunting You

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THE CREDIT DEATH SPIRAL — When Data Furnishers Get It Wrong