OPINION & ORDER Gia Sessa of Putnam Valley (“Plaintiff”) brings this putative class action suit against Linear Motors, LLC d/b/a/ Curry Hyundai Subaru, Hudson Valley Federal Credit Union (“HVFCU”), CULA, LLC (collectively, “Lessor Defendants”), and TransUnion, LLC, (collectively, “Defendants”), alleging that Lessor Defendants hid certain fees and taxes paid by Plaintiff upon leasing a car in violation of the Consumer Leasing Act, 15 U.S.C. §§1667, et seq.; New York Vehicle and Traffic Law, N.Y. Veh. & Traf. §415, et seq.; and the New York General Business Law, N.Y. Gen. Bus. §349, and alleging that Defendant TransUnion failed to accurately report Plaintiff’s debt obligations vis-à-vis her vehicle lease in violation of the Fair Credit Reporting Act, 15 U.S.C. §1681, et seq. (“FCRA”), and New York General Business Law §380, et seq. (“NY FCRA”). (See First Am. Compl. (“FAC”) (Dkt. No. 4).) Before the Court is TransUnion’s Motion for Summary Judgment. (Not. of Mot. (Dkt. No. 111).) For the following reasons, TransUnion’s Motion is granted. I. Background A. Factual Background The following facts are taken from the Parties’ statements pursuant to Local Civil Rule 56.1, specifically TransUnion’s 56.1 Statement (Def.’s Rule 56.1 Statement (“Def.’s 56.1″) (Dkt. No. 113)) and Plaintiff’s 56.1 Counterstatement (Pl.’s Rule 56.1 Counterstatement (“Pl.’s 56.1 Counterstatement”) (Dkt. No. 123-20 (filed under seal), Dkt. No. 126 (redacted))), and the admissible evidence submitted by the Parties. The facts are recounted “in the light most favorable to” Plaintiff, the non-movant. Wandering Dago, Inc. v. Destito, 879 F.3d 20, 30 (2d Cir. 2018) (citation and quotation marks omitted). The facts as described below are in dispute only to the extent indicated.1 1. The FCRA The FCRA requires that credit reporting agencies (“CRAs”) prepare “consumer reports,” known otherwise as credit reports, using “reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.” 15 U.S.C. §1681e(b). The FCRA does not, however, require CRAs to review the underlying legal documents giving rise to a consumer’s debt obligations to verify the legal validity thereof prior to reporting said debt on the consumer’s credit report. (Pl.’s 56.1 Counterstatement 32.) The FCRA also imposes various obligations on organizations that supply data to CRAs, known as “furnishers.” See 16 C.F.R. §660.2. Relevant to this case, the law bars furnishers from supplying information to CRAs it “knows or has reasonable cause to believe…is inaccurate.” 15 U.S.C. §1681s-2(a)(1)(A); see also 12 C.F.R. §1022.42(a) (regulations requiring furnishers to “establish and implement reasonable written policies and procedures regarding the accuracy and integrity of the information” furnished to CRAs). The Consumer Financial Protection Bureau (“CFPB”), which oversees credit ratings practices, also requires furnishers to provide CRAs with information that “correctly[] [r]eflects the terms of and liability for the account.” 12 C.F.R. §1022.41(a)(1). The FCRA does not pertain only to institutions; to the contrary, it encourages consumers to participate in the credit reporting process, animated by the belief that “enhancing consumers’ access to their credit reports is an effective step towards ensuring an accurate credit reporting system.” S. Rep. No. 103-209, at 5 (1993). To enable such participation, the FCRA affords consumers two mechanisms to dispute the accuracy of information listed on a credit report. First, a consumer can submit a dispute directly to a CRA, who must then forward the dispute to the appropriate furnisher. See 15 U.S.C. §1681i(a)(1)(A). Second, a consumer can submit a dispute directly to the furnisher. See id. §1681s-2(a)(8). 2. TransUnion’s General Processes Pursuant To Its CRA Obligations Pursuant to the charge that a CRA use “reasonable procedures” to ensure accuracy, TransUnion will review a furnisher prior to accepting any information from that furnisher, a vetting process commonly referred to as “credentialing.” (See Pl.’s 56.1 Counterstatement 68.) TransUnion’s multi-faceted credentialing process includes but is not limited to reviewing the furnisher’s reputation as well as the nature of the data to be furnished. (See id.
63-67.) If a furnisher passes the credentialing process, TransUnion also requires a furnisher to “contractually agree to, among other things, comply with all of the obligations imposed on that furnisher,” including all applicable statutory and regulatory obligations under the FCRA, regulations promulgated thereunder, and equivalent state laws and regulations. (Id. 69.) Importantly, per the agreement, data are also supposed to be furnished in a particular way, namely an industry-wide format called “Metro2,” (id. 74), which “allows a furnisher to report a balloon payment obligation for any type of account with a deferred payment obligation, including an auto lease,” (id. 41). After TransUnion credentials and signs an agreement with a furnisher, it “conducts an onboarding process…with a furnisher to test and verify the integrity of the data the company intends to furnish.” (Def.’s 56.1 75.)2 Once the data furnisher begins providing TransUnion with information, the company continues to monitor, screen, and validate the quality and integrity of data furnished, including using proprietary techniques and strategies. (See id.
