Honestly.com - a new CRA?

15 U.S.C. 1681a(d) defines a consumer report as "any written, oral, or other communication of any information 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 which is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumer's eligibility for (A) credit or insurance to be used primarily for personal, family, or household purposes; (B) employment purposes; or (C) any other purpose authorized under section 604 [§ 1681b]."

15 U.S.C. 1681f defines a consumer reporting agency as "any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties, and which uses any means or facility of interstate commerce for the purpose of preparing or furnishing consumer reports."

Based on these definitions, I think http://www.honestly.com/ is a new CRA and thus subject to the provisions of the FCRA. 

What is honestly.com, you ask?  According to their website, "Honestly.com is an online resource for building, managing, and researching professional reputation, using community-contributed, professional reviews. Honestly.com reviews help you get the inside scoop on other business professionals, providing candid assessments of coworkers, potential hires, business partners, and more. By contributing Honestly.com reviews, you can share your knowledge of other professionals, giving credit where credit is due, and valuable feedback where needed."

In other words, you supply the scoop on past and current co-workers, professionals you have had dealings with, etc.  Honestly.com then assembles that data into a professional reputation about that particular person, so you can determine whether you want to do business with or work with that person.  Sounds like it falls squarely within the definition of consumer reporting agency to me.  Wonder if Honestly.com realizes that?

If Honestly.com is a CRA, that means they must comply with the requirements of the FCRA, including providing complete copies of your consumer report on request (and payment of a small fee) and investigating any disputes made by consumers regarding the contents of the consumer's consumer report.  Wonder if Honestly.com is set up to handle requests from consumers for copies of their credit reports and/or to investigate disputes made regarding errors in their reports?  Anybody know?  Anybody game to find out?