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The Commission argued that the district court erred in holding that an insurance company cannot take “adverse action” against a consumer, as that term is defined in the Fair Credit Reporting Act, in connection with an initial offer of insurance. The brief disputes the district court’s holding, pursuant to which there would be no adverse action, even if, as a result information in a consumer report, the insurance company offered only a higher price or more onerous terms than it would have offered if the information in the report had been more favorable. The brief explains that the district court’s analysis is based on a misinterpretation of both the Act’s wording and its legislative history.