—
An error in a consumer report can occur at the source, including the Social Security Administration, tradeline, or Office of Foreign Assets Control databases, long before the record ever reaches a reseller. By the time that information reaches a lender or automotive dealer, the business delivering the report may have had no role in creating the mistake and no access to the database where it began.
Attorney Maureen Shannon sees that divide between transmission and control as one of the central questions in modernizing the Fair Credit Reporting Act. As general counsel of Open Dealer Exchange, she advises executives and the board on FCRA litigation, class actions, cybersecurity and regulatory risk.
Her résumé includes senior positions at Rivian Automotive and Rocket Mortgage and work across automotive finance, fintech, consumer lending, privacy, intellectual property and compliance.
“Nearly two decades of advising companies through litigation, regulatory change and fast-moving business decisions have taught me that accountability must track both conduct and control,” Shannon said. “If a company did not create the data and cannot correct the source, the law should take that operational reality into account.”
She is now carrying that argument into government relations, working with lawmakers, lobbyists, and automotive trade groups to build support for H.R. 8141, the Fair Credit Reporting Reseller Accuracy Act. The proposed change is narrow, but the line it draws could affect how legal risk is allocated across the consumer reporting chain.
“Consumer protection and fair reseller accountability do not have to be competing objectives,” Shannon said. “A reseller should be responsible for transmitting information accurately. It should not be responsible for an upstream error it did not create and cannot correct at the source.”
Resellers Sit in the Middle of a System They Do Not Control
The Fair Credit Reporting Act defines a reseller as a type of consumer reporting agency that assembles and merges information from other consumer reporting agencies without maintaining the combined database to produce new reports. That places the reseller between the source and the end user.
The underlying information may be traced to creditors, government records or other furnishers.
Maureen Shannon points to records generated via the Social Security Administration and Office of Foreign Assets Control, along with tradeline information, as data a reseller may transmit without controlling the source.
“The legal analysis should begin with access and control,” Shannon said. “Who created the information, who can verify it against the original source, and who has the ability to correct it? A reseller can be held responsible for what happens in its hands, but it cannot reach backward and alter a database it does not control.”
She believes that distinction matters in all cases where consumer reports are utilized, including in automotive finance, where dealers and lenders rely on them daily. Shannon argues that responsibility should follow each participant’s actual role.
The Bill Separates Accuracy Duties From Upstream Errors
Rep. Mike Lawler, R-N.Y., introduced H.R. 8141 on March 27, 2026, with Rep. Josh Gottheimer, D-N.J. Reps. Daniel Meuser, R-Pa., and Ann Wagner, R-Mo., later joined as cosponsors.
The bill would add a reseller-specific provision to Section 607 of the FCRA. It requires “reasonable procedures to assure maximum possible accuracy” before transmission and limits liability when a reseller accurately communicates information obtained from another consumer reporting agency.
The House Financial Services Committee ordered the bill reported favorably, as amended, by voice vote on June 30.
As of late August 2026, it had not received a vote by the full House.
“The bill does not say accuracy no longer matters,” Attorney Maureen Shannon said. “It says resellers must use reasonable procedures to assure maximum possible accuracy. The liability limitation applies when the reseller accurately communicates information obtained from another consumer reporting agency. Those two provisions have to be read together.”
Consumer Advocates See a Dangerous Gap
The National Consumer Law Center presented a sharply different reading during an April 16 hearing before the House Financial Services Subcommittee on Financial Institutions. The organization argued that H.R. 8141 would give resellers too broad a defense, including when transmitted information appeared facially illogical or came from a source with known reliability problems.
That criticism deserves a direct answer because inaccurate reports can affect access to a car, a home or employment. Shannon says the objection overlooks how the bill’s accuracy requirement and liability limitation work together.
“If this bill passes, accuracy is still required and consumers are still protected,” Shannon said. “The question is whether liability is being placed on the party that caused the error and is in a position to correct it.”
Consumers can dispute an item with the reporting company and the furnisher that supplied it. The reporting company generally must investigate and report the result to the consumer.
Resellers also have duties under 15 U.S.C. § 1681i(f). H.R. 8141 would not erase that framework; the fight concerns liability for data accurately transmitted from elsewhere.
A Courtroom Victory May Not Correct the Underlying Report
Lawsuits remain an important FCRA enforcement mechanism. Consumers may seek damages and attorney fees for violations. Shannon worries that a consumer’s practical objective can get lost once the dispute moves into litigation.
“A lawsuit may determine who pays for an alleged violation, but the consumer still needs the information corrected,” Shannon said. “If the reseller did not create the error and cannot change the source record, naming that reseller may not be the fastest route to the result the consumer actually needs.”
Legal representation can be necessary when a company fails to investigate or correct inaccurate information. Shannon’s point is that litigation should not become a substitute for tracing an error to its source. An effective system should preserve legal remedies while making correction clear and easy for consumers.
Attorney Maureen Shannon Sees Education as the First Practical Defense
Shannon’s proposed first line of defense begins before a dispute reaches court. Consumers need to know how to obtain reports, identify errors and contact the organization responsible for the disputed information.
The Consumer Financial Protection Bureau advises consumers to dispute inaccurate or incomplete information with both the reporting company and the furnisher. The reporting company generally must investigate and forward relevant material to the company that supplied the information.
“What would truly be a win for consumers is widespread education about how to access free credit reports and information about how to contact each data furnisher to correct their report if there is an error,” Shannon said. Useful education should explain where to obtain reports, document a dispute and identify the furnisher.
Better consumer education does not replace regulation, she said. It would make existing protections more visible and easier to use.
Accountability Should Follow Control, Not Proximity
Consumers should not carry the consequences of inaccurate information. Attorney Maureen Shannon also questions liability for a business that accurately performed its role in the credit ecosystem: Did the reseller alter the information? Did the reseller follow reasonable procedures to ensure it does not introduce errors into the data it transports? Which entity is able to correct the source?
“The goal is not less accountability,” Maureen Shannon Attorney said. “It is accountability that follows the facts. Every participant should answer for the part of the process it controls.”
That framework preserves consequences for misconduct while recognizing the limits of an intermediary’s access. It also keeps the consumer’s practical objective of correcting the record, at the center.
Government Relations Is Becoming Part of Executive Legal Leadership
Attorney Maureen Shannon’s work on H.R. 8141 moves beyond interpreting regulations to helping inform how they are written. She is working with lobbyists, congressional offices and trade associations, including the National Automobile Dealers Association and National Consumer Reporting Association, to build support and develop a position statement.
The effort reflects her work as a strategic legal partner for rapid-growth entities, spanning governance, compliance, privacy, financing and litigation.
“I am accessible and connect with people by translating complex legal concepts into actionable intel to make smart decisions at the speed of the game,” Shannon said.
Government relations applies that skill to a different audience. Lawmakers need to understand how a rule operates in commercial reality, while companies need a candid account of what reform can accomplish.
Shannon is not asking Congress to choose between consumer protection and fair reseller accountability. She wants FCRA reform to preserve meaningful dispute rights and accuracy standards while assigning legal responsibility to the party that created or controls the underlying information.
The next step, in her view, is a system that directs consumers to the source of an error and directs accountability there, too.
“Better regulation should be accompanied by better consumer education,” Maureen Shannon explained during a recent interview about FCRA reform. “Consumers need to know how to find an error, identify where it came from and reach the organization that can fix it. That is how protection becomes practical.”
—
