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Third‐Party Investigations and the Fair Credit Reporting Act

George R. Kramer (Vice president and associate general counsel at the Securities Industry Association in Washington, D.C.)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 1 March 2000


This article discusses a recent interpretation of the Fair Credit Reporting Act by the Federal Trade Commission. Under this interpretation, a range of potentially onerous requirements may be triggered when third parties are used to investigate potential employee misconduct. This article particularly focuses on how this interpretation might conflict with a broker‐dealer's compliance obligations.


Kramer, G.R. (2000), "Third‐Party Investigations and the Fair Credit Reporting Act", Journal of Investment Compliance, Vol. 1 No. 3, pp. 45-53.




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