Federal Trade Commission v. Manager, Retail Credit Company, Miami Branch Office

515 F.2d 988, 169 U.S. App. D.C. 271, 1975 U.S. App. LEXIS 15874
CourtCourt of Appeals for the D.C. Circuit
DecidedFebruary 28, 1975
Docket73-1844
StatusPublished
Cited by81 cases

This text of 515 F.2d 988 (Federal Trade Commission v. Manager, Retail Credit Company, Miami Branch Office) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Federal Trade Commission v. Manager, Retail Credit Company, Miami Branch Office, 515 F.2d 988, 169 U.S. App. D.C. 271, 1975 U.S. App. LEXIS 15874 (D.C. Cir. 1975).

Opinion

MacKINNON, Circuit Judge:

The Federal Trade Commission (FTC) applied to the District Court for enforcement of an administrative subpoena duc-es tecum requiring the Retail Credit Company (Retail) to produce documentary evidence for a Commission investigation of the practices of certain consumer reporting agencies under the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq. Following a trial the District Court ruled that the FTC, like other Government agencies seeking consumer credit reports regulated by the FCRA, must obtain a court order or the permission of affected consumers in order to compel disclosure of the documents. 1 Because we conclude that the FTC has special statutory power incident to its role as enforcer of the FCRA, we reverse.

I

In 1970 Congress appended to the Consumer Credit Protection Act, 15 U.S.C. § 1601 et seq., a number of provisions collectively known as the Fair Credit Reporting Act. Section 602 of the FCRA recognized that “[cjonsumer reporting agencies have assumed a vital role in assembling and evaluating consumer credit and other information on consumers” and affirmed the “need to insure that [such] agencies exercise their grave responsibilities with fairness, impartiality, and a respect for the consumer’s right to privacy.” The congressional prescription was a comprehensive series of restrictions on the disclosure and use of credit information assembled by consumer reporting agencies. Section 604 identifies three instances in which reporting agencies may furnish credit reports: (1) in response to an appropriate court order; (2) by permission of consumers whose credit ratings are documented in the reports sought; and (3) to a person with a legitimate business interest in the information. 2 Section 608 *990 allows disclosure of limited portions of the reports — essentially identifying information — to governmental agencies unable to qualify under any of the subsections of section 604. 3 The Act attaches special restrictions to the preparation and disclosure of investigative consumer reports 4 and requires that an agency apprise a consumer who makes an appropriate request of the nature and substance of information in his file, the sources of the data, and the identity of parties to whom it is released. 5

Section 621 sets forth an elaborate scheme for administrative enforcement of the FCRA. Subsection (a) imposes upon the Federal Trade Commission the responsibility for enforcing compliance with the requirements of the FCRA with respect to the preponderance of consumer reporting agencies and affirms the Commission’s right to use its customary procedural, investigative and enforcement powers. 6 Subsection (b) commits enforcement obligations to specified Government agencies where enumerated institutions or statutes are involved. 7 Though each of the agencies listed in (b) is authorized to use all authority conferred on it by law to enforce the FCRA *991 in its respective province, none wields powers as comprehensive as that of the FTC.

On April 1, 1972, as part of an ongoing investigation of the practices of certain consumer reporting agencies, the FTC issued a subpoena duces tecum to the Manager of the Miami Branch Office of the Retail Credit Company. 8 The corn-pany assembles and sells data bearing on *992 an individual’s credit rating, fitness for employment, and qualifications for insurance, including personal information on character, reputation, and life style. Specification 7 of the subpoena requested production of the complete files of all consumers who since January 1 had directed the Miami Branch Office to release information in their files. Specification 9 sought the complete files of all individuals investigated by four named credit investigators during certain periods of time. Retail complied with the entirety of the subpoena save specifications 7 and 9; in a letter dated May 8, 1972, the company explained that the disclosures requested in those paragraphs would violate both section 604 of the Fair Credit Reporting Act and the rights of privacy of those consumers whose reports the Commission was seeking. 9

The FTC petitioned the District Court for an order compelling compliance with its subpoena and for a declaration, pursuant to 28 U.S.C. § 2201 (1959), that section 621 of the FCRA permits voluntary compliance with Commission requests for the production of consumer reports. Retail Credit counterclaimed for a declaration that the Act forbids distribution of consumer reports unless the request is supported by court order or consumer authorization. Because the FTC managed to obtain some of Retail’s consumer reports distributed to insurance companies after the initial pleadings were filed, Retail amended its counterclaim to include a request for a declaration that no person or organization could release its reports unless the requirements of section 604 were followed.

At trial Commission witnesses testified to the need for prompt access to consumer reports in investigations of reporting agencies’ compliance with the FCRA. Retail responded that the language of the statute did not allow disclosure by administrative subpoena, that the procedures which the Act specified were adequate for the Commission’s task, and that the privacy considerations which had prompted passage of the FCRA militated against any unauthorized or unnecessary disclosure. On April 23, 1973, the District Court entered an order denying the Commission’s power to compel production of Retail’s consumer reports by administrative subpoena. Instead the court treated the FTC petition as an application for a court order under section 604 of the FCRA and proceeded to grant the application, subject to Commission notification, by mail and publication, of the consumers whose reports were sought, in order to afford them an opportunity to refuse disclosure. Because the court denied the FTC direct access to Retail’s consumer reports, it similarly disapproved the agency’s efforts to secure the reports from third parties who had purchased them for legitimate business purposes, and forbad that line of attack in the future.

II

The Fair Credit Reporting Act speaks with apparent ambiguity of the FTC’s power to obtain consumer reports from reporting agencies. Section 604 establishes a seemingly exclusive catalogue of the instances in which reports may be disclosed — “A consumer reporting agency *993

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. David Vyner
846 F.3d 1224 (D.C. Circuit, 2017)
Ross v. Federal Deposit Insurance
625 F.3d 808 (Fourth Circuit, 2010)
McSherry v. Capital One FSB
236 F.R.D. 516 (W.D. Washington, 2006)
Rodriguez v. Mellon Bank, N.A. (In Re Rodriguez)
218 B.R. 764 (E.D. Pennsylvania, 1998)
DKT Memorial Fund Ltd. v. Agency for International Development
691 F. Supp. 394 (District of Columbia, 1988)
Caddell Const. Co., Inc. v. Lehman
599 F. Supp. 1542 (S.D. Georgia, 1985)
Union Carbide Corp. v. Superior Court
679 P.2d 14 (California Supreme Court, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
515 F.2d 988, 169 U.S. App. D.C. 271, 1975 U.S. App. LEXIS 15874, Counsel Stack Legal Research, https://law.counselstack.com/opinion/federal-trade-commission-v-manager-retail-credit-company-miami-branch-cadc-1975.