Background Check Disclosure Forms Must Be Clear, Standalone

The FCRA requires employers who obtain a consumer report on job applicants to disclose that process "in a document that consists solely of the disclosure." The Ninth Circuit had previously held in Syed that "a prospective employer violates Section 1681(b)(2)(A) when it procures a job applicant's consumer report after including a liability waiver in the same document as the statutorily mandated disclosure" because that would not be a document that "consist[s] 'solely' of the disclosure."
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