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CFPB Finalizes 2026 Increase to Fair Credit Reporting Act Disclosure Fee Cap

By A.J. Dhaliwal, Mehul Madia & Maxwell Earp-Thomas on December 18, 2025
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On December 15, the CFPB issued a final rule amending Regulation V under the Fair Credit Reporting Act to update the maximum amount a consumer reporting agency may charge a consumer for certain file disclosures. The amendment implements FCRA’s annual inflation adjustment requirement and sets the ceiling for calendar year 2026.

The final rule establishes a maximum allowable charge of $16.00 for 2026, reflecting a $0.50 increase from the prior year, and takes effect January 1, 2026. The Bureau calculated the adjustment by applying changes in the Consumer Price Index for All Urban Consumers from September 1997 through September 2025 to the statute’s $8.00 baseline and rounding the result to the nearest fifty cents, as required by the Fair Credit Reporting Act.

Under FCRA, nationwide consumer reporting agencies and nationwide specialty consumer reporting agencies must provide consumers with free file disclosures in specified circumstances, including once every 12 months upon request. When a consumer is not entitled to a free disclosure, the Act permits agencies to impose a reasonable charge, subject to the annually adjusted cap. 

Putting It Into Practice: Even as the CFPB’s broader enforcement posture continues to contract, the Bureau is still carrying out statutorily mandated regulatory functions (previously discussed here). Consumer reporting agencies and other market participants that facilitate consumer file disclosures should confirm that fee schedules, consumer-facing disclosures, and operational systems reflect the $16.00 cap beginning January 1, 2026.

Photo of A.J. Dhaliwal A.J. Dhaliwal

A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm’s Washington, D.C. office.

Read more about A.J. DhaliwalEmail
Photo of Mehul Madia Mehul Madia

Mehul Madia, special counsel in the firm’s Washington, D.C. office, provides deep consumer finance and fintech expertise to clients, leveraging more than 15 years’ of public and private sector experience.

Read more about Mehul MadiaEmail
Photo of Maxwell Earp-Thomas Maxwell Earp-Thomas

Max is an associate in the Finance & Bankruptcy Practice Group in the firm’s Orange County office.

Read more about Maxwell Earp-ThomasEmail
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Consumer Finance and Fintech Blog
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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