More Authorities Regarding GLBA Privacy and the FCRA

Last month PLA posted the FTC staff’s “Tatelbaum II” and “Gowen” letters, pursuant to PLA’s mission to facilitate the availability of important FCRA and other privacy-law authorities. PLA now posts the “Throne” letter, which is of both historic significance and continuing relevance. We believe that “Throne” remains relevant in downsell arrangements and, more generally, in establishing standards regarding the “consumer request” exception to the definition of a “consumer reporting agency.” See Forty Years of Experience with the Fair Credit Reporting Act, footnote 49 and Section 603(f)-4(E). PLA will be posting additional notable letters and other privacy-law authorities from time to time.