Alder Holdings, LLC
On December 11, 2020, the Consumer Financial Protection Bureau (Bureau) and the Arkansas Attorney General filed a proposed stipulated final judgment and order in the United States District Court for the Eastern District of Arkansas against Alder Holdings, LLC (Alder). Alder is a Utah-based company that sells home-security and alarm systems, primarily door-to-door, throughout the country and has sold its products and services to over 115,000 customers. The complaint alleged that Alder, in extending credit to its customers for its home-alarm products and services, violated the Fair Credit Reporting Act and Regulation V by charging customers who had lower credit scores higher activation-fees, but failing to provide those customers with the required risk-based pricing notice. Arkansas also alleged that Alder violated the Consumer Financial Protection Act of 2010 (CFPA). If entered by the court, the settlement would require Alder to pay a $600,000 civil money penalty, $100,000 of which will be offset if Alder pays that amount to settle related litigation with the State of Arkansas that is currently pending in state court in Arkansas. The settlement would also require Alder to provide proper notices under FCRA.