A lot of people either forget or never realize that the Fair Credit Reporting Act applies to more than just Equifax, Experian and Trans Union, the traditional "big three" credit bureaus. The Fair Credit Reeporting Act defines "consumer reporting agency" as any person who assembles or evaluates consumer reports. A "consumer report" is any written, oral or other communication by a consumer reporting agency bearing on a consumer's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics or mode of living.
I recently learned of the Fraud Center Network, which is a website that threatens blacklisting to any consumer that does not pay for his or her online purchases. If a seller has a beef with a purchaser because the purchaser does not pay as promised, the seller reports it to the Fraud Center Network. The Fraud Center then e-mails the buyer who allegedly did not pay and gives him or her a chance to pay before being blacklisted. Most pay at this point, regardless of whether they owe the money. The ones that don't pay get blacklisted. Subscribers to the Fraud Center Network have access to the entries supplied by aggrieved sellers for a fee, regardless of accuracy.
It seems to me that the compilation of information regarding consumers supplied to the Fraud Center Network's subscribers are consumer reports. The Fraud Center Network would then be considered a consumer reporting agency and subject to the Fair Credit Reporting Act.
I would like to know more about the Fraud Center Network. A Westlaw search shows no decisions I cases involving them. A google search did not reveal much more. If any of you have had any dealings with them, please contact me.