📘 FERPA Violation
FERPA protects educational records and personally identifiable information (PII).
Schools, servicers, and guarantors may not disclose this information to third parties (including credit bureaus) without written consent or a valid legal exception.
🚫 No consent = unlawful disclosure
🚫 No exception = FERPA violation
⚖️ Permissible Purpose Violation (FCRA)
Under the FCRA, a furnisher must have a legitimate permissible purpose to:
Access consumer data
Share information with CRAs
Continue reporting an account
If a student loan is charged off, transferred, or no longer enforceable, continued reporting may lack permissible purpose.