
CFPB’s Recent Interpretive Rule Encourages States to Enact Fair Credit Reporting Laws
When courts or administrative agencies opine on whether a federal statute preempts state law, they usually do so in the wake of the statute’s enactment. But the U.S. Consumer Financial Protection Bureau’s (CFPB) interpretive rule issued mid-summer regarding the Fair Credit Reporting Act’s limited preemption of state laws comes 52 years after the FCRA became