A troublesome problem involving so-called "other information" under the Fair Credit Reporting Act has been lurking ever since the privacy provisions were included in the Gramm-Leach-Bliley Act.

The fair credit law distinguishes between "experience or transactional information" and "other information." The former is information relating to a person's own experience or transactions with a consumer and is not subject to the fair credit laws. In consequence, a person is not restricted under this law from sharing the information with any other person, including an affiliate.

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