Do you use a third party service to conduct background checks on
job applicants or employees? If yes, then you should take
note of new forms which employers are required to use for this
purpose, effective January 1, 2013. The new forms, which were
originally issued last year, had to be revised due to errors, so
you'll need to make sure you have the most recent, corrected
versions of the forms.
By way of background, the Fair Credit Reporting Act
("FCRA") is a federal law that imposes requirements on
employers who use third party Consumer Reporting Agencies
("CRA's) to obtain "consumer reports" (i.e.,
background checks, reference checks, credit checks) and
investigative reports on job applicants or current employees.
The FCRA was previously administered by the Federal Trade
Commission, but is now administered by the Consumer Financial
Protection Bureau ("CFPB"), which issued the revised
forms. Employers should expect heightened scrutiny of FCRA
compliance under