On May 22, 2018, Vermont’s first-in-the-nation law imposing disclosure and data security obligations on data brokers (H.764) went into effect. Calls for legislation to regulate data brokers are not new – at the federal level, the FTC proposed “targeted legislation” of the industry in a 2012 report on consumer privacy, and reiterated that proposal in a 2014 report specifically focused on data brokers. But until now, no data-broker-specific legislation had been enacted.

In addition to imposing a number of new requirements on data brokers (outlined below), the law also requires credit reporting agencies to provide and remove “security freezes” prohibiting the release of consumer credit reports at no charge.

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