Are resellers required to respond to file disclosure requests under the FCRA?

Under the Fair Credit Reporting Act (FCRA), resellers, which are entities that aggregate consumer credit information from multiple sources and then sell that compiled information, are indeed exempt from the requirement to respond to file disclosure requests made by consumers. This specification is crucial to understand within the framework of the FCRA.

The FCRA allows consumers to request their credit file information from consumer reporting agencies, which typically include credit bureaus. However, resellers are not considered primary consumer reporting agencies or direct sources of consumer information; instead, they function as intermediaries. As a result, they do not have an obligation to provide disclosures directly to consumers, as they do not maintain individual consumer files in the same manner as the original reporting agencies.

This distinction underscores the role that primary credit bureaus play in maintaining consumer credit records and the limitations placed on resellers in the context of consumer rights under the FCRA. Therefore, resellers are indeed exempt from the requirement to respond to such disclosures, making the choice regarding this exemption the correct understanding of their obligations under the FCRA.