A Ninth Circuit Court of Appeal’s ruling has made already strict background check requirements even more stringent. The court held that the disclosure required under the federal Fair Credit Reporting Act (FCRA) can consist only of the FRCA disclosure; it can’t contain any additional information, including the disclosure required under California’s Investigative Consumer Reporting Agencies Act (ICRAA) (Gilberg v. California Check Cashing Stores, LLC,913 F.3d 1169 (9th. Cir. 2019)).