I'm working on an FCRA audit using the Interagency Examination Procedures. Our bank is currently obtaining credit reports for loan requests and on prospective employees. When reviewing our contract with the CRA that we utilize, it explicitly allows us to obtain reports on consumers for credit transactions. It does not state that we may obtain reports for employment purposes. Should we be going back to the CRA for an updated contract?

I think you already read my answer on a similar post in the HR forum a couple of days ago.

Yes I did read you other post - thank you!