Reynolds v. Hartford Financial Services Group, Inc.

REINHARDT, Circuit Judge:

Under the Fair Credit Reporting Act (“FCRA”), insurance companies are required to send adverse action notices to consumers whenever they increase the rates for insurance on the basis of information contained in consumer credit reports. 15 U.S.C. §§ 1681a(k)(l)(B)(i), lbSlmta). 1 The principal question before us is straightforward: Does FCRA’s adverse action notice requirement apply to the rate first charged in an initial policy of insurance? We hold that the answer is yes: The Act requires that an insurance company send the consumer an adverse action notice whenever a…