UNITED
STATES OF AMERICA
October 23, 1997 Ms. Vivian L. Solganik
Dear Ms. Solganik: This responds to your letter dated September 17, 1997, in which you seek the views of the Commission staff on two questions arising under the amended Fair Credit Reporting Act ("FCRA"). We quote each of your questions verbatim, and answer as follows: 1. In the context of using consumer reports for employment purposes, is it permissible to give the notice required under Section 604(b)(3) in the same document as is used to give the adverse action notice which is required under Section 615(a)(2)?
2. Is it permissible to combine in one form the disclosure required under Section 604(b)(2)(A) with the consumer authorization which is required in Section 604(b)(2)(B), assuming that the disclosure to the consumer and the consumer's authorization are the only elements of the form?
The views set forth in this informal opinion letter are those of the staff, and are not binding on the Commission. Sincerely yours, Clarke W. Brinckerhoff |