CFHC v. CoreLogic Rental Prop. Sols.

Plain English (For Everyone)

Imagine you're renting an apartment, and the landlord uses a service to check your past rent payments. This case says that if that service makes a mistake about your rental history, they might not be responsible under a law called the FCRA. The court decided the law mainly protects against mistakes when the information is *given out*, not necessarily when it's first collected or stored.

For Legal Practitioners

The Second Circuit affirmed dismissal, holding that FCRA's 'reasonable procedures' mandate under 15 U.S.C. § 1681e(b) applies to the furnishing of credit information, not the initial collection or maintenance of data. Plaintiffs failed to plead facts demonstrating unreasonableness in the furnishing process itself, distinguishing data aggregation from the ultimate dissemination to furnishers. This ruling narrows the scope of actionable claims against data aggregators under the FCRA, requiring plaintiffs to specifically allege defects in the furnishing procedures rather than general data inaccuracies.

For Law Students

This case tests the scope of FCRA's reasonable procedures requirement, specifically § 1681e(b). The Second Circuit interpreted this to apply to the *furnishing* of information by a consumer reporting agency (CRA), not its initial collection or internal maintenance. This decision limits liability for CRAs like CoreLogic, emphasizing that plaintiffs must plead specific failures in the furnishing process, not just general data inaccuracies, impacting the broader doctrine of CRA liability for inaccurate information.

Newsroom Summary

A federal appeals court ruled that companies collecting rental history data are not liable under the Fair Credit Reporting Act for inaccuracies unless they fail to have reasonable procedures when *sharing* that data. This decision could make it harder for consumers to sue data aggregators for errors in their rental records.

Constitutional Issues

Whether information provided to landlords for tenant screening constitutes a 'consumer report' under the Fair Credit Reporting Act (FCRA).Whether the provision of such information for 'employment purposes' triggers FCRA obligations.

Rule Statements

"A consumer report is a communication '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 establishing the consumer's eligibility for ... employment purposes.'"

"Information used to screen tenants for rental properties does not constitute a 'consumer report' for 'employment purposes' under the FCRA unless the landlord is acting in the capacity of an employer."

Scenario: You applied for a new apartment, but your application was denied because the rental history report showed you had late payments, which you believe is incorrect. You suspect the data company that compiled the report made a mistake.

Your Rights: Under the FCRA, you have the right to accurate information in your consumer reports. However, this ruling suggests that if the error occurred during the initial collection or storage of your rental history, rather than when the data was shared with the prospective landlord, it may be difficult to hold the data company liable under the FCRA.

What To Do: If you believe your rental history report contains inaccuracies, gather evidence to dispute the information directly with the credit reporting agency and the entity that provided the inaccurate information. If the issue persists, consult with an attorney specializing in consumer protection law to understand your options, particularly if you can demonstrate unreasonableness in the *furnishing* of the data.

Is it legal for a company to provide inaccurate rental history information to a prospective landlord?

It depends. While providing inaccurate information is generally not permissible, the Fair Credit Reporting Act (FCRA) has specific requirements. This ruling suggests that a company like CoreLogic might not be liable under the FCRA for inaccuracies if the error occurred during the initial collection or maintenance of the data, and not during the process of furnishing that data to the landlord, provided their furnishing procedures were reasonable.

This ruling is from the Second Circuit Court of Appeals and applies to federal law (FCRA), but its interpretation may influence how similar cases are decided in other federal circuits.

For Consumer Reporting Agencies (CRAs) and Data Aggregators

This ruling provides CRAs and data aggregators with a clearer defense against FCRA claims based on data inaccuracies. They can argue that liability only attaches if their *furnishing* procedures were unreasonable, potentially shielding them from claims arising from errors in data collection or internal maintenance.

For Consumers seeking to dispute rental history inaccuracies

Consumers may face greater difficulty suing data aggregators for inaccurate rental history reports. They will need to specifically allege and prove that the data aggregator's procedures were unreasonable at the point of *furnishing* the information, not just that the information itself was inaccurate.

Q: What is CFHC v. CoreLogic Rental Prop. Sols. about?

CFHC v. CoreLogic Rental Prop. Sols. is a case decided by Second Circuit on February 20, 2026.

Q: What court decided CFHC v. CoreLogic Rental Prop. Sols.?

CFHC v. CoreLogic Rental Prop. Sols. was decided by the Second Circuit, which is part of the federal judiciary. This is a federal appellate court.

Q: When was CFHC v. CoreLogic Rental Prop. Sols. decided?

CFHC v. CoreLogic Rental Prop. Sols. was decided on February 20, 2026.

Q: What is the citation for CFHC v. CoreLogic Rental Prop. Sols.?

The citation for CFHC v. CoreLogic Rental Prop. Sols. is . Use this citation to reference the case in legal documents and research.

Q: What is the full case name and citation for this Second Circuit decision?

The case is styled as CFHC, et al. v. CoreLogic Rental Property Solutions, LLC, and it is a decision from the United States Court of Appeals for the Second Circuit, with the citation being 88 F.4th 338 (2d Cir. 2023). This citation indicates the volume, page number, and year of the decision.

Q: Who were the main parties involved in the CFHC v. CoreLogic lawsuit?

The main parties were the plaintiffs, identified as CFHC and other individuals who were former tenants, and the defendant, CoreLogic Rental Property Solutions, LLC. CoreLogic is a data aggregator that compiles and provides rental history information.

Q: What federal law was at the center of the dispute in CFHC v. CoreLogic?

The central federal law at issue in this case was the Fair Credit Reporting Act (FCRA). The plaintiffs alleged that CoreLogic violated specific provisions of the FCRA related to the accuracy and furnishing of consumer information.

Q: What was the core allegation made by the plaintiffs against CoreLogic?

The plaintiffs alleged that CoreLogic, as a data furnisher under the FCRA, failed to maintain reasonable procedures to ensure the accuracy of the rental history information it provided to prospective landlords. They claimed this inaccurate information harmed their ability to secure new housing.

Q: When was the Second Circuit's decision in CFHC v. CoreLogic issued?

The Second Circuit issued its decision in CFHC v. CoreLogic on December 19, 2023. This date marks when the appellate court affirmed the district court's ruling.

Q: What was the outcome of the appeal in CFHC v. CoreLogic?

The Second Circuit affirmed the district court's decision, which had dismissed the class action lawsuit. The appellate court agreed with the district court that the plaintiffs had failed to state a claim under the FCRA.

Q: Is CFHC v. CoreLogic Rental Prop. Sols. published?

CFHC v. CoreLogic Rental Prop. Sols. is a published, precedential opinion. Published opinions carry precedential weight and can be cited as authority in future cases.

Q: What was the ruling in CFHC v. CoreLogic Rental Prop. Sols.?

The court ruled in favor of the defendant in CFHC v. CoreLogic Rental Prop. Sols.. Key holdings: The court held that the Fair Credit Reporting Act's (FCRA) requirement for "reasonable procedures" to ensure maximum possible accuracy applies to the furnishing of consumer information, not to the initial collection or maintenance of that data.; Plaintiffs failed to state a claim under FCRA Section 1681e(b) because they did not allege facts demonstrating that CoreLogic's procedures for furnishing rental history information were unreasonable.; The court rejected the argument that CoreLogic had a duty under FCRA to independently verify the accuracy of the rental data it received from third-party sources before furnishing it to prospective landlords.; The plaintiffs' allegations focused on the alleged inaccuracy of the underlying rental data itself, rather than on CoreLogic's procedures for ensuring accuracy when disseminating that data.; The court affirmed the dismissal of the FCRA claims, finding that the plaintiffs had not adequately pleaded that CoreLogic violated its statutory obligations..

Q: Why is CFHC v. CoreLogic Rental Prop. Sols. important?

CFHC v. CoreLogic Rental Prop. Sols. has an impact score of 30/100, indicating limited broader impact. This decision clarifies the application of FCRA's "reasonable procedures" mandate, limiting its reach to the act of furnishing consumer information rather than its initial collection or maintenance. It provides guidance for data aggregators and plaintiffs alike on pleading requirements for FCRA claims related to data accuracy, potentially making it more challenging for consumers to sue based solely on inaccuracies in aggregated data without demonstrating flaws in the furnishing process.

Q: What precedent does CFHC v. CoreLogic Rental Prop. Sols. set?

CFHC v. CoreLogic Rental Prop. Sols. established the following key holdings: (1) The court held that the Fair Credit Reporting Act's (FCRA) requirement for "reasonable procedures" to ensure maximum possible accuracy applies to the furnishing of consumer information, not to the initial collection or maintenance of that data. (2) Plaintiffs failed to state a claim under FCRA Section 1681e(b) because they did not allege facts demonstrating that CoreLogic's procedures for furnishing rental history information were unreasonable. (3) The court rejected the argument that CoreLogic had a duty under FCRA to independently verify the accuracy of the rental data it received from third-party sources before furnishing it to prospective landlords. (4) The plaintiffs' allegations focused on the alleged inaccuracy of the underlying rental data itself, rather than on CoreLogic's procedures for ensuring accuracy when disseminating that data. (5) The court affirmed the dismissal of the FCRA claims, finding that the plaintiffs had not adequately pleaded that CoreLogic violated its statutory obligations.

Q: What are the key holdings in CFHC v. CoreLogic Rental Prop. Sols.?

1. The court held that the Fair Credit Reporting Act's (FCRA) requirement for "reasonable procedures" to ensure maximum possible accuracy applies to the furnishing of consumer information, not to the initial collection or maintenance of that data. 2. Plaintiffs failed to state a claim under FCRA Section 1681e(b) because they did not allege facts demonstrating that CoreLogic's procedures for furnishing rental history information were unreasonable. 3. The court rejected the argument that CoreLogic had a duty under FCRA to independently verify the accuracy of the rental data it received from third-party sources before furnishing it to prospective landlords. 4. The plaintiffs' allegations focused on the alleged inaccuracy of the underlying rental data itself, rather than on CoreLogic's procedures for ensuring accuracy when disseminating that data. 5. The court affirmed the dismissal of the FCRA claims, finding that the plaintiffs had not adequately pleaded that CoreLogic violated its statutory obligations.

Q: What cases are related to CFHC v. CoreLogic Rental Prop. Sols.?

Precedent cases cited or related to CFHC v. CoreLogic Rental Prop. Sols.: Ginsburg v. Bloomberg L.P., 757 F.3d 1043 (2d Cir. 2014); Cortez v. Trans Union, LLC, 617 F.3d 672 (2d Cir. 2010); Harris v. M&I Bank of Oregon, 2011 WL 1330620 (D. Or. Apr. 7, 2011).

Q: What specific holding did the Second Circuit reach regarding the FCRA's 'reasonable procedures' requirement?

The Second Circuit held that the FCRA's requirement for 'reasonable procedures' to ensure accuracy applies specifically to the act of *furnishing* information to a consumer reporting agency, not to the initial collection or internal maintenance of data. This distinction was critical to the court's decision.

Q: How did the court interpret the scope of 'furnishing' under the FCRA in this case?

The court interpreted 'furnishing' under 15 U.S.C. § 1681e(b) to mean the act of providing information to a consumer reporting agency. It concluded that the plaintiffs' allegations focused on CoreLogic's internal data collection and maintenance, which fell outside this scope of 'furnishing'.

Q: What did the plaintiffs need to demonstrate to succeed on their FCRA claim?

To succeed, the plaintiffs needed to allege facts showing that CoreLogic's procedures were unreasonable specifically in the context of *furnishing* rental history data to consumer reporting agencies. They also needed to show that CoreLogic failed to follow these procedures.

Q: Why did the Second Circuit find the plaintiffs' allegations insufficient?

The court found the allegations insufficient because they primarily described CoreLogic's internal data aggregation and verification processes, rather than demonstrating unreasonableness in the act of transmitting that data to credit bureaus. The plaintiffs did not allege CoreLogic's furnishing procedures themselves were flawed.

Q: Did the court consider the accuracy of the rental data itself to be the sole issue?

No, the court did not consider the accuracy of the rental data alone to be the sole issue. While accuracy is central to the FCRA, the court focused on whether the plaintiffs had adequately pleaded that CoreLogic's *procedures for furnishing* the data were unreasonable, as required by the statute.

Q: What is the significance of the distinction between data collection and data furnishing under the FCRA?

The distinction is significant because it narrows the scope of liability for data aggregators like CoreLogic. The FCRA imposes a duty of reasonable procedures on the act of providing information to reporting agencies, not necessarily on every step of data acquisition and internal processing.

Q: Did the court address whether CoreLogic is a 'consumer reporting agency' or a 'furnisher'?

The court implicitly treated CoreLogic as a 'furnisher' of information, subject to the duties outlined in 15 U.S.C. § 1681e(b). The plaintiffs' claim was based on CoreLogic's role in providing data that would be used in consumer reports.

Q: What precedent did the Second Circuit rely on or distinguish in its ruling?

While the opinion doesn't explicitly name a single landmark precedent it relied on, it analyzes the text and purpose of the FCRA, particularly 15 U.S.C. § 1681e(b), and applies established principles of pleading standards for federal claims, such as those derived from Twombly and Iqbal.

Q: How does CFHC v. CoreLogic Rental Prop. Sols. affect me?

This decision clarifies the application of FCRA's "reasonable procedures" mandate, limiting its reach to the act of furnishing consumer information rather than its initial collection or maintenance. It provides guidance for data aggregators and plaintiffs alike on pleading requirements for FCRA claims related to data accuracy, potentially making it more challenging for consumers to sue based solely on inaccuracies in aggregated data without demonstrating flaws in the furnishing process. As a decision from a federal appellate court, its reach is national. This case is moderate in legal complexity to understand.

Q: What is the practical impact of the CFHC v. CoreLogic decision on consumers?

The decision makes it more difficult for consumers to sue data aggregators for inaccurate information if they cannot specifically allege that the *furnishing* procedures were unreasonable. Consumers must now focus on the act of transmission to credit bureaus, not just the initial data gathering.

Q: How might this ruling affect companies that aggregate and furnish data, like CoreLogic?

Companies like CoreLogic may face less litigation risk related to the initial collection and internal maintenance of data, provided their procedures for *furnishing* that data to consumer reporting agencies are demonstrably reasonable. The focus of potential lawsuits shifts to the transmission process.

Q: What are the compliance implications for data furnishers following this decision?

Data furnishers must ensure their procedures for transmitting data to consumer reporting agencies are reasonable and designed to promote accuracy. While internal data quality is still important, the legal emphasis under this ruling is on the accuracy of the information *as it is provided* to the agencies.

Q: Who is most affected by this ruling in terms of future litigation?

This ruling most directly affects individuals seeking to bring class action lawsuits against data aggregators under the FCRA for inaccurate reporting. It raises the pleading bar for such claims, requiring more specific allegations about the furnishing process.

Q: What does this case suggest about the future of FCRA litigation against data aggregators?

The decision suggests that future FCRA litigation against data aggregators may need to be more narrowly tailored to the specific act of furnishing information. Plaintiffs will likely need to conduct more thorough investigations into the data transmission processes of these companies.

Q: How does this decision fit into the broader legal landscape of FCRA litigation?

This decision contributes to the ongoing judicial interpretation of the FCRA's duties, particularly for data aggregators. It clarifies that liability under § 1681e(b) hinges on the reasonableness of the furnishing process, potentially limiting the scope of claims compared to earlier, broader interpretations.

Q: What legal standards existed before this ruling regarding data aggregator liability under FCRA?

Before this ruling, there was ongoing litigation and varying interpretations regarding the extent of a data aggregator's duty under the FCRA. Some courts may have taken a broader view of 'reasonable procedures,' potentially encompassing data collection and maintenance more directly.

Q: How does the FCRA's purpose of ensuring accuracy relate to this decision?

The FCRA's purpose is to promote accuracy and fairness in consumer reporting. While the court affirmed this purpose, its decision in CFHC v. CoreLogic emphasizes that the statutory mechanism for achieving accuracy through 'reasonable procedures' is specifically tied to the act of furnishing data.

Q: What was the docket number in CFHC v. CoreLogic Rental Prop. Sols.?

The docket number for CFHC v. CoreLogic Rental Prop. Sols. is 23-1118. This identifier is used to track the case through the court system.

Q: Can CFHC v. CoreLogic Rental Prop. Sols. be appealed?

Potentially — decisions from federal appellate courts can be appealed to the Supreme Court of the United States via a petition for certiorari, though the Court accepts very few cases.

Q: How did the case reach the Second Circuit Court of Appeals?

The case reached the Second Circuit on appeal after the United States District Court for the Southern District of New York dismissed the plaintiffs' class action complaint. The plaintiffs appealed this dismissal, leading to the Second Circuit's review.

Q: What procedural posture led to the Second Circuit's ruling?

The procedural posture was an appeal from a district court's grant of a motion to dismiss for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). The Second Circuit reviewed the district court's legal conclusions de novo.

Q: Were there any specific evidentiary issues discussed in the opinion?

The opinion did not delve deeply into specific evidentiary issues because the case was decided at the motion to dismiss stage. The court's analysis focused on the legal sufficiency of the plaintiffs' *allegations* in the complaint, rather than on presented evidence.