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They might be.

My first response was to say no, and quote the definitions directly from the FCRA. But, upon reading them, I would prefer you interpret them for yourself, or better yet, refer to an attorney familiar with reading law.

FCRA 15 USC 1681a sec. 603(d)(1)(2) and (3) which refers to sec. 604(g)(3)...that is where it gets sketchy (for me) and what MIGHT apply to your question.

You can print yourself off a copy of the FCRA at www.ftc.gov

Sorry to be evasive, but if you need an answer, it is best to get a correct one.

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