The United States District Court in Oregon recently dismissed the class action complaint of plaintiff Daniel Walker, who alleged his potential employer violated the disclosure and pre-adverse action notification requirements of the Fair Credit Reporting Act (FCRA). Although Walker claimed that the companys disclosure language was overshadowed by information about investigative consumer reports, the court reasoned that the disclosure was not itself an investigative report closure and also found presenting the disclosure in a separate document along with the authorization did not destroy the stand-alone character of the disclosure.
