What is an Investigative Consumer Report?

An investigative consumer report is a type of consumer report that includes information about an individual’s character, general reputation, personal characteristics, or lifestyle, typically gathered through personal interviews with acquaintances, previous employers, landlords, or other knowledgeable sources. These reports are frequently used in employment and housing contexts and are governed by federal and state consumer protection laws.

Under the Fair Credit Reporting Act (FCRA), and California Civil Code, investigative reports do not include specific factual credit data obtained directly from creditors or consumer reporting agencies. Instead, they focus on subjective and behavioral information that may influence decisions about a person’s suitability for a job or tenancy.

Examples of investigative consumer reports include:

  • A credit report from agencies such as TransUnion, Experian, or Equifax;
  • A tenant screening report detailing rental history, based on landlord feedback or housing court records;
  • A background check report outlining a person’s criminal history;
  • A combined report that includes rental and criminal history, as well as credit information;
  • A risk score or recommendation from a tenant screening company based on landlord-selected criteria;
  • A reference check report involving contact with former landlords, employers, or others listed on an application.

When employers use these reports, especially those derived from interviews, they must follow additional requirements under the FCRA (15 U.S.C. §1681d). These include:

  • Providing written notice to the individual that an investigative consumer report may be obtained;
  • Informing them of their right to request more detailed disclosures about the report;
  • Supplying a summary of the scope and substance of the report upon request.

These protections are intended to promote transparency, protect consumer privacy rights, and ensure fair treatment in decision-making processes that rely on personal background information.