[newbee05]

Would someone please review my analysis below and let me know if you believe it to be accurate?

The furnisher rules under FCRA/FACTA apply to institutions who:
1. Report credit history information on any individual (regardless of the loan’s purpose), and
2. Reports this information to a National Consumer Reporting Agency which is an Agency that provides this information to a third party to be used to determine the individual’s eligibilty for (a) credit to be used primarily for personal, family, or household purposes, (b) employment purposes, or any other purpose authorized under section 604 [1681b].

If a bank reports credit information to an Agency that only provides the information to third parties who intend to use the information to determine the eligibility of individuals for commercial credit, the furnisher rules would not apply because the information is not being provided to an agency that meets the definition of a National Consumer Reporting Agency.

[rcooper]

Is there an effective way to ensure the third parties are only using the information as intended – for commercial credit?

[Author]

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