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FCRA Compliance — Even Without Credit Checks

November 5, 2025by Barbara Flynn0

At People First, we’re often asked great questions that help business owners stay compliant and confident in their hiring practices.

 

This week, one of our clients reached out with a common concern:

 

“We use a background screening company, but we don’t do any credit checks. Do we still need to follow the Fair Credit Reporting Act (FCRA) rules?”

 

It’s a great question — and the answer is yes.

Even if a background report doesn’t include credit information, the FCRA still applies when a third-party screening company is used. That means employers must provide applicants with:

  • A clear written disclosure and authorization form before running a background check.
  • A pre-adverse action notice if something in the report may impact hiring decisions.
  • A final adverse action notice if the decision not to hire (or to terminate) is made.

 

After reviewing our guidance and the sample forms we provided, our client replied:

 

“Thank you so much for the clarification and for sending the sample forms. I really appreciate your help and the detailed guidance. This was very helpful.”

 

That’s what we love to hear — compliance made clear, and clients who feel confident and supported.
At People First, we believe peace of mind should come standard with every policy, process, and person we serve.

Barbara Flynn

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