Friday, May 7, 2021 On April 29, 2021, the FTC announced a $20 million settlement with Vivint Smart Home, Inc. (Vivint), a national seller of in-home security and monitoring systems, based on violations of the Fair Credit Reporting Act, the FTC Act, and the Red Flags Rule. Per the FTC, the settlement is the largest one to date for an FCRA case. Vivint is well-known for employing a large commission-based door-to-door sales force. According to the allegations of the FTC complaint, its door-to-door sales practices exposed the company to liability. In order to complete a “new customer registration,” a Vivint sales representative must request and obtain from a credit reporting agency a consumer report to evaluate the creditworthiness of the potential customer. The FTC’s complaint details two methods employed by Vivint’s sales representatives to qualify an otherwise unqualified consumer to purchase a product.