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On December 1, 2016, Parker Hannifin Corporation and CLARCOR Inc. announced that the companies have entered into a definitive agreement under which Parker will acquire CLARCOR for approximately $4.3 billion in cash, including the assumption of net debt. The transaction has been unanimously approved by the board of directors of each company. Upon closing of the transaction, expected to be completed by or during the first quarter of Parker’s fiscal year 2018, CLARCOR will be combined with Parker’s Filtration Group to form a leading and diverse global filtration business. Bass, Berry & Sims has served CLARCOR as primary corporate and securities counsel for 10 years and served as lead counsel on this transaction. Read more here.

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FCPA: 2016 Year in Review & 2017 Enforcement Predictions

A review of trends and developments in FCPA as well as a look ahead into what to expect for 2017. This report aims at providing corporate leaders and companies with the knowledge they need to comply with the FCPA and avoid litigation in 2017.

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CFPB Warns Furnishers of Consumer Data

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September 6, 2013

Earlier this week, the Consumer Financial Protection Bureau (CFPB) reminded entities that furnish information to consumer reporting agencies (CRAs) about their obligation to investigate consumer disputes. The Fair Credit Reporting Act (FCRA) requires CRAs to notify the furnisher when a consumer disputes the accuracy of information that was provided by the furnisher to the CRA. That notification must include "all relevant information" provided by the consumer in support of the dispute. In turn, the FCRA requires the furnisher to conduct an investigation of the dispute; report the results to the CRA; and, if the furnished information was inaccurate, provide corrected information to every CRA that received the inaccurate information.

The thrust of the CFPB bulletin appears to be recent updates to e-OSCAR – the system used by the three largest credit bureaus to communicate with furnishers about credit disputes. In December 2012, the CFPB issued a report which highlighted that e-OSCAR did not allow CRAs to provide furnishers with documents submitted by consumers in support of their disputes. The credit bureaus recently have upgraded e-OSCAR so that it is now capable of sending furnishers documents provided by consumers. The only novel guidance in the bulletin issued by the CFPB this week is the advice that each furnisher maintain a system capable of receiving information provided by CRAs regarding disputes, "including supporting documentation."

Companies that provide consumer information to CRAs should ensure that their systems are compliant with the newly upgraded e-OSCAR functionality. Furnishers of consumer information also should ensure that their dispute resolution procedures take into account the documentation that previously was unavailable through e-OSCAR. Finally, in addition to their obligation to investigate disputes transmitted from CRAs, furnishers are reminded that the FCRA also requires furnishers to maintain written policies and procedures to investigate disputes received directly from consumers. The CFPB bulletin demonstrates the renewed focus that the federal regulators – the CFPB and Federal Trade Commission – have placed on FCRA compliance by furnishers and all other entities subject to the Act.

If you have any questions about the content of this alert, please contact the author listed above or any of the FCRA team members listed here.


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