This Note first reviews the purpose and function of a consumer reporting agency and discusses the provisions of the FCRA that pertain to consumer reporting agencies and judicial interpretations of those provisions. It then analyzes the Bryant decision in light of the policies behind the FCRA and criticizes the effect of the FCRA in sheltering reporting creditors. This Note concludes that the Bryant decision should be read narrowly to reflect the true spirit of the FCRA. Consumer reporting agencies must be permitted to function as mere conduits of information without incurring liability for inaccuracies over which they have no control. Finally, this Note recommends that the FCRA should be amended to make reporting creditors liable when they are the source of inaccuracies in consumer credit reports.
Barbara C. Sherland,
The Functions of Consumer Reporting Agencies Under the Fair Credit Reporting Act—Bryant v. TRW, Inc., 689 F.2d 72 (6th Cir. 1982),
59 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol59/iss2/9