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Only information that is a matter of public record can be included in an investigative consumer report according to the Fair Credit Reporting Act.

Restrictions on investigative consumer reports: Section 1681l

Whenever a consumer reporting agency prepares an investigative consumer report, no adverse information in the consumer report (other than information which is a matter of public record) may be included in a subsequent consumer report unless such adverse information has been verified in the process of making such subsequent consumer report, or the adverse information was received within the three-month period preceding the date the subsequent report is furnished

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