In Longman v. Wachovia Bank, N.A. — F.3d —-, 2012 WL 6604538 (2d Cir. 2012), the Court of Appeals for the Second Circuit followed Nelson to find no private right of action under 15 USC 1681s-2(a).
Although we have not previously addressed whether the Fair Credit Reporting Act provides a private cause of action for violations of § 1681s–2(a), the statute plainly restricts enforcement of that provision to federal and state authorities. Indeed, the stat-ute provides that subsection (a) “shall be enforced exclusively … by the Federal agencies and officials and the State officials identified in section 1681s of this title.” 15 U.S.C. § 1681s–2(d) (emphasis added). Thus, the district court correctly concluded, as many other courts have held, that there is no private cause of action for violations of § 1681s–2(a). Accord, e.g., Boggio v. USAA Federal Sav. Bank, 696 F.3d 611, 615–16 (6th Cir.2012); Sanders v. Mountain Am. Fed. Credit Union, 689 F.3d 1138, 1147 (10th Cir.2012); SimmsParris v. Countrywide Fin. Corp., 652 F.3d 355, 358 (3d Cir.2011); Chiang, 595 F.3d at 35; Saunders v. Branch Banking & Trust Co. of Va., 526 F.3d 142, 149 (4th Cir.2008); Nelson v. Chase Manhattan Mort. Corp., 282 F.3d 1057, 1059 (9th Cir.2002). Because the complaint only alleges viola-tions of subsection (a)—i.e., knowingly disclosing false information, see § 1681s–2(a)(1), failing to correct false information, see § 1681s–2(a)(2), and failing to investigate a dispute filed directly with a furnisher of information, see § 1681s–2(a)(8)—the district court properly granted summary judgment on Longman’s Fair Credit Reporting Act claims.