This decision reverses a summary judgment for defendant, finding a triable issue of fact as to whether defendant willfully violated the FCRA’s requirement that an employer provide a job applicant a stand alone disclosure of its potential use of credit reports for employment screening. (15 USC 1681b(b)(2)(A).) Wilful for this purpose includes reckless conduct that increases the risk of violation substantially above mere negligence. Here, defendant delegated to a person who knew little about the FCRA the task of assuring FCRA compliance with the result that the disclosure contained an extraneous paragraph of information, contrary to the FCRA’s clear requirement. Both the clarity of the requirement and the delegation of the compliance task to an unskilled person raised a question of fact as to whether defendant’s conduct was reckless.