In a case involving a plaintiff whose name is familiar to many in the industry, a District Court judge in Oklahoma has granted a defendant’s motion to dismiss a Fair Credit Reporting Act case alleging a credit reporting agency did not include complete and accurate information related to the plaintiff’s credit report.
The background: The plaintiff filed the lawsuit pro se, alleging the defendant, a consumer reporting agency that compiles telecommunications and utility payment data, violated the FCRA’s disclosure requirements.
- The plaintiff obtained a copy of his consumer disclosure from the defendant in October 2025. He claimed the disclosure was incomplete and inaccurate because several fields associated with seven different accounts contained missing or partial information. Specifically, the plaintiff pointed to truncated account numbers, missing “sub-service type” information, and the absence of past-due amounts.
- The plaintiff argued that these omissions demonstrated the defendant failed to “clearly and accurately disclose” all information in his consumer file as required by the FCRA. He further alleged the violations were either willful or negligent and claimed emotional distress, confusion, and out-of-pocket expenses.
The ruling: Judge Scott L. Palk of the District Court for the Western District of Oklahoma agreed with the defendant and dismissed the complaint, concluding the plaintiff failed to plead sufficient facts showing the defendant withheld information that existed in the consumer’s file.
- A key issue in the case was the plaintiff’s reliance on blank or incomplete fields in the disclosure as evidence that required information had been omitted. The court rejected that reasoning.
- The judge noted that consumer reporting agencies generally collect information from data furnishers and disclose what those furnishers provide. If a furnisher never provided certain information, the reporting agency would have nothing to disclose in response to a consumer request.
- This reasoning played an important role in the court’s analysis of the truncated account numbers. The plaintiff cited several cases and an FTC advisory opinion suggesting consumers are entitled to full account numbers in disclosures. However, the court emphasized the plaintiff never alleged that the underlying furnishers provided the full numbers to the reporting agency.
- The judge wrote that holding a credit reporting agency liable in that scenario “would lead to absurd results,” particularly if the agency had no way of knowing whether the furnisher supplied the information in truncated form.
- The same logic applied to the allegedly missing “sub-service type” and past-due fields. The plaintiff never alleged that the accounts involved prepaid services or that any past-due amounts actually existed.
