On September 25, 2023, the Consumer Financial Protection Bureau (“CFPB”) began its most substantial Fair Credit Reporting Act (“FCRA”) rulemaking yet with an outline of proposed changes to Regulation V, which implements FCRA, ahead of the Bureau’s Small Business Advisory Review Panel.1 The proposals under consideration could have a substantial impact on the data brokerage industry, if implemented. In this Legal Update, we look at the key components of the CFPB’s initial proposals for revising Regulation V.
