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Citation Number
06-84, 06-100

Joint brief of the United States and the Federal Trade Commission, as amici curiae in these consolidated cases, urging vacatur and remand in Safeco, and reversal in GEICO. The brief argues that, under the Fair Credit Reporting Act, the phrase “willful noncompliance” encompasses both knowing violations and reckless disregard for the law. The brief also argues that an insurance company must provide an applicant with an adverse action notice whenever that company offers a consumer a higher rate than it would have offered if the consumer’s report had been more favorable.