CFPB Amicus Brief on Credit Reporting Accuracy

Detected March 18th, 2026

Summary

The CFPB filed an amicus brief in a case against TransUnion, arguing that credit reporting companies must disclose the source of personal identifying information like phone numbers and that accuracy requirements apply to such data. This action is part of the CFPB's ongoing efforts to hold credit reporting companies accountable for inaccurate data.

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What changed

The Consumer Financial Protection Bureau (CFPB) has filed an amicus brief in a lawsuit against TransUnion. The brief argues that credit reporting companies are legally required to disclose the source of personal identifiers such as phone numbers and that the Fair Credit Reporting Act's accuracy requirements extend to this type of information. This filing aims to counter TransUnion's arguments that these disclosures and accuracy mandates do not apply to personal identifiers, which the CFPB contends are crucial for consumers to identify and correct errors on their credit reports.

This action underscores the CFPB's commitment to enforcing the FCRA and ensuring credit reporting companies are held accountable for providing accurate data. Compliance officers should note the CFPB's stance on the scope of disclosure and accuracy requirements for personal identifiers. While this brief is in support of a specific case, it signals the agency's interpretation of existing law, which could influence future enforcement actions and litigation against credit reporting agencies and data brokers. Regulated entities should review their practices regarding the collection, reporting, and dispute resolution of personal identifying information to ensure compliance with the FCRA as interpreted by the CFPB.

What to do next

Review policies on disclosure of personal identifier sources in credit reports
Ensure accuracy requirements under FCRA are applied to all personal identifiers
Monitor litigation and CFPB guidance related to credit reporting accuracy

Source document (simplified)

Credit reports serve as economic gatekeepers for millions of Americans seeking to buy a home, start a business, or get a car loan. When these reports contain inaccuracies or mistakes, consumers can face serious financial consequences - from loan denials to higher interest rates.

The Fair Credit Reporting Act establishes clear legal requirements for credit reporting companies. They must ensure the accuracy of the detailed dossiers they compile on Americans, provide consumers access to their information, and give consumers the right to correct inaccurate data. These core provisions protect consumers by helping ensure that credit report information is about the right person and that errors don't lead to real-world consequences like denial of employment.

We have seen how credit reporting companies have repeatedly tried to get federal courts to bless numerous dubious arguments to try and shirk responsibility when their bad data leads to consumers getting harmed.

Today, we filed an amicus brief to ensure that credit reporting companies aren’t successful in writing loopholes into the law. In this case, a consumer claims that the credit reporting company, TransUnion, included a phone number that did not belong to him on his credit report, failed to provide him with the source of the bad phone number, and also listed his actual phone number in the credit report of someone else, subjecting him to intrusive debt collection calls.

TransUnion has argued in response that they are not required to provide people the source of certain information in their reports like phone numbers, Social Security numbers, addresses, or even their name itself. Our amicus brief explains that this is incorrect. Congress clearly required consumer reporting companies to disclose the source of phone numbers and similar information, and courts have found that the law’s protections apply to information in credit reports, which plainly includes consumers’ personal identifying information.

Congress sought to promote transparency in the credit reporting system by requiring that consumer reporting companies disclose the sources of information in a consumer’s credit report. Without access to this information, consumers are unable to find out who may be reporting wrong information about them. And when people’s data gets mixed up with someone else’s, it’s not just a minor inconvenience but a problem that can have far reaching consequences for their financial lives.

TransUnion also claims that the requirement to make sure that the information in a credit report is accurate doesn’t apply to personal identifiers like phone numbers. The CFPB’s brief explains why Congress’s accuracy requirements are not so limited in scope.

Our brief in this matter is part of the CFPB’s efforts to ensure that credit reporting companies are held accountable when they break the law. Last week, the CFPB sued the credit reporting company Experian for unlawfully failing to properly investigate consumer disputes. Last year, the CFPB proposed a rule to stop data brokers from selling Americans' sensitive personal and financial information to scammers, stalkers, and spies by making clear that data brokers are covered by the Fair Credit Reporting Act when they sell sensitive consumer information. The CFPB also issued guidance last year making clear to industry that false, incomplete, and old information must not appear in background check reports, and that a person’s complete credit report must be provided to them upon request. And in 2023, the CFPB took action against a rental screening subsidiary of TransUnion for, among other things, failing to take steps to assure the maximum possible accuracy of eviction records in rental background check reports.

The CFPB will continue to hold credit reporting companies accountable when they fail to do their job.

The case is Arora v. TransUnion, No. 23-2590 (7th Cir.).

Read CFPB’s amicus brief.

If you have had a problem with a consumer financial product or service, you can submit a complaint with the CFPB.

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Jan. 17, 2025

12:40 PM EST

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