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Court Rules that in Determining Accuracy under the FCRA, the Entire Tradeline Must Be Considered


A recent case in the Northern District of Georgia confirms that when evaluating whether a tradeline in a consumer report is accurate, a court will consider the entire record in context and not focus on individual elements in isolation. See Ellis v. Warehouse Home Furnishings Distribs., 2020 U.S. Dist. LEXIS 225572 (N.D. Ga. 2020).

The Plaintiff in this case contended that the Defendant inaccurately reported her tradeline to credit reporting agencies (“CRAs”). Specifically, she alleged that Defendant inaccurately reported a scheduled monthly payment of $215 on her closed account, when Defendant should have been reporting a scheduled monthly payment of $0.00. As a result, she claimed that Defendant committed negligent and willful violations of the Fair Credit Reporting Act (the “FCRA”). In its motion for summary judgment, Defendant argued that Plaintiff’s claims against it fail because the information provided to the CRAs was accurate.

In order for a court to grant summary judgment, the movant must show that “…. there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). A party arguing that a fact is or is not genuinely disputed must support that assertion by citing to particular parts of materials in the record. FULL ARTICLE