In response to generally good ideas of 'pooling' information and/or
centralizing it among landlords, I think Bill Cullen already responded
to that some time ago: it's a legal nightmare for landlords and their
attorneys.  Generally, once landlords pool or provide credit reporting
information, he or she could easily be defined as either a credit
reporting agency or, as they generally already are, a 'furnisher of
information.'  Both are subject to the federal Fair Credit Reporting
Act, a complex law that can really trap the unwary, with substantial
penalties.  If I were a landlord's attorney, I'd advise my client to
stay ten country miles away from becoming anything remotely resembling a
credit reporting agency.  If you don't believe me on the complexities of
FCRA, check it out online at www.ftc.gov.os/statutes/fcra.htm#623 and
try to figure out where you'd fall.

That said, the onus is on the credit reporting industry to change to
provide the ability for a tenant to purchase what I guess would be
called an "access credit report," a report that can then be 'accessed'
for a period of time and for a much smaller fee by participating and
cooperating landlords.  Now, try moving an industry toward that goal, as
well as standardizing what information is to be contained in the report.
Sounds good, may even be fertile for true money-making, but you must
move an established industry and win over the participation of landlords
and tenants alike.  Given the abuses already occurring and the chance of
making the industry change, I think the ordinance may provide a better
go at it.

Gregory Luce
St. Paul

-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On
Behalf Of [EMAIL PROTECTED]
Sent: Wednesday, September 22, 2004 4:28 PM
To: [EMAIL PROTECTED]; [EMAIL PROTECTED]
Subject: Re: [Mpls] Minneapolis to restrict rental application fees.


I wonder if landlords "pooling" applicant information and sharing it
among  
themselves is a violation of federal privacy law? If that is the case, 
landlords  must buy individual records from credit recording companies
to protect  
themselves. 
 
Bill Dolly
Kenny
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