Join us for the first episode in a special three-part series covering the CFPB’s intention to propose new rules under the Fair Credit Reporting Act (FCRA). In this episode, Troutman Pepper Partners Chris Willis, Dave Gettings, Ethan Ostroff, and Kim Phan explore the historical events that led us to this point, the next steps in the rulemaking process, the expected timeline for a final rule, how the CFPB is coordinating with the FTC and other regulators, and the expected proposed rulemaking regarding credit header data and data brokers.

Transcript: CFPB’s Rulemaking Under the FCRA (Podcast)


Stay tuned for the next two episodes in this series. In our second episode, our panel will discuss the regulation of credit header data and the potential impact on the FCRA and consumer reporting agencies, as well as users and data brokers. And the final episode of our series will focus specifically on data brokers and the possibility of regulating data brokers under the FCRA, the effect it can have on data brokers as well as other types of entities, users, consumer reporting agencies, and resellers.

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Photo of David M. Gettings David M. Gettings

Dave primarily defends consumer class actions. In a client’s words with respect to an FCRA class action he was defending: “He is a forceful and prepared advocate when necessary, but also a peacemaker when that better serves the client. And he never, ever

Dave primarily defends consumer class actions. In a client’s words with respect to an FCRA class action he was defending: “He is a forceful and prepared advocate when necessary, but also a peacemaker when that better serves the client. And he never, ever misses a detail or an angle.”

Photo of Chris Willis Chris Willis

Chris is the co-leader of the Consumer Financial Services Regulatory practice at the firm. He advises financial services institutions facing state and federal government investigations and examinations, counseling them on compliance issues including UDAP/UDAAP, credit reporting, debt collection, and fair lending, and defending…

Chris is the co-leader of the Consumer Financial Services Regulatory practice at the firm. He advises financial services institutions facing state and federal government investigations and examinations, counseling them on compliance issues including UDAP/UDAAP, credit reporting, debt collection, and fair lending, and defending them in individual and class action lawsuits brought by consumers and enforcement actions brought by government agencies.

Photo of Ethan G. Ostroff Ethan G. Ostroff

Ethan Ostroff’s practice focuses on financial services litigation and consumer law compliance counseling. Ethan is part of the firm’s national practice representing consumer-facing companies of all types in defense of individual and class action claims and counseling them on compliance with federal and

Ethan Ostroff’s practice focuses on financial services litigation and consumer law compliance counseling. Ethan is part of the firm’s national practice representing consumer-facing companies of all types in defense of individual and class action claims and counseling them on compliance with federal and state laws.

Photo of Kim Phan Kim Phan

Kim is a privacy and data security lawyer who counsels companies in federal and state privacy and data security statutes and regulations. Her work encompasses strategic planning and guidance for companies to incorporate privacy and data security considerations throughout product development, marketing, and

Kim is a privacy and data security lawyer who counsels companies in federal and state privacy and data security statutes and regulations. Her work encompasses strategic planning and guidance for companies to incorporate privacy and data security considerations throughout product development, marketing, and implementation.