The FTC also released a staff report entitled "Forty Years of Experience with the Fair Credit Reporting Act." This report provides background on the FTC’s role in enforcing the FCRA, and includes a section-by-section summary of the agency’s interpretations of the FCRA.
In announcing the withdrawal of the Commentary and release of the staff report, the FTC stated that the Commentary "has become partially obsolete since it was issued 21 years ago." The new staff report deletes several interpretations in the Commentary that have since been repealed, modified or otherwise amended, and adds updated interpretations to reflect changes in the law since the Commentary was released in 1990. The FTC stated that, given the Commentary’s staleness, it "does not believe it is appropriate to transfer the Commentary."