What is the basis for affiliates to share information among themselves?

The basis for affiliates to share information among themselves is grounded in their own transactions or experiences related to the consumers with whom they interact. Under the Fair Credit Reporting Act (FCRA), affiliates are permitted to exchange information for a variety of purposes, including consumer credit information and marketing practices, provided that the information shared pertains directly to the experiences they have had with those consumers.

When affiliates have a legitimate interest in sharing information—such as through transactions that involve credit or lending—they are allowed to do so without necessarily obtaining consent from the consumer each time. This can help streamline processes such as assessing creditworthiness or facilitating marketing initiatives based on relevant consumer data.

The other options do not accurately reflect the foundational principles of how information can be shared among affiliates. For instance, sharing information solely based on marketing strategies or independent consumer reviews does not encompass the full legal framework provided by the FCRA for affiliate sharing. Additionally, sharing information only when prompted by the consumer does not align with the practices outlined in the FCRA, as the law allows for proactive use of transactional information.