ChexSystems and the CRA Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: Does the definition of nationwide CRA include ChexSystems? Does it also apply to reporting systems such as Chexsystems or just credit reporting agencies? Would ChexSystems be considered a CRA?
Answer: ChexSystems, and similar companies, are consumer reporting agencies, but are not nationwide consumer reporting agencies. The distinction matters only in connection with a few specific provisions in the FCRA and FACT Act that relate only to nationwide CRAs, rather than all CRAs. For that reason, it's always important to read the provision carefully to see if it applies only when a nationwide CRA (one of the big three - TransUnion, Experian, Equifax) is involved or if it applies when any CRA is involved.
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