Rhode Island has a quirky statute that arguably requires any consumer reporting agency who provides credit reports or information to state residents to register with the Department of State – Business Services Division.

I strongly encourage all background screening companies doing business in Rhode Island to work with their legal counsel to determine if they should register.  Do not be mislead by use of the term “credit bureau” in the statute.

Title 6, Chapter 6-13.1-24 requires “Any credit bureau doing business in this state shall immediately register in the office of the secretary of state….”  The definitions section (section 6-13.1-20) defines a credit bureau similar to the language in section 603(f) of the Fair Credit Reporting Act.  Which is why, arguably, any background screening company doing business in Rhode Island which includes providing credit reports or information should consider whether to register with the state.

From personal experience we know that there is at least one serial plaintiff in Rhode Island who has filed a number of claims against companies alleging they failed to register with the state.  While the statutory penalties may not seem significant, the cost of defending such a claim, which could lead to litigation or arbitration, should be considered.

Click here to view the Registration of a Credit Bureau form.

I am happy to discuss this with background screening companies considering whether to register.