No Double-Dipping Under FCRA
In an oldie but goodie, an FTC blog from Feb 2017 warns employers who rely on credit checks not to double-dip. In other words, if an employer requests a consumer report for one purpose, the employer should not then use the report for another purpose.
The FTC explains that, when an employer receives a consumer report from a CRA, it must certify to the CRA the purpose for which the report will be used, and the report should only be used for that purpose. The FTC provides two examples: “if you get a report for a membership determination, you can’t then use it to make a credit decision. Or if you get a report to determine eligibility for a government benefit, you can’t then give it to a different government agency to make another eligibility determination.”
The importance, according to the FTC? Transparency. Consumers cannot accurately track how their credit information is being used when a single credit report is used for multiple purposes.