In three articles posted on this site (linked here , here and here) we suggested the Landlord Credit Bureau is legally obligated to comply with the Security Freeze provisions of the Consumer Reporting Act. It has come to our attention that the Security Freeze provisions of the Consumer Reporting Act are not legally in force in Ontario and therefore by definition the Landlord Credit Bureau is not obligated to comply with these measures. Our suggestions otherwise were based on the false assumption the laws in question were in force, a mistake we deeply regret.
Specifically, section 12.4 of the Consumer Reporting Act creates a procedure for consumers to request a security freeze on their file with a consumer reporting agency such as the Landlord Credit Bureau. While this provision has been enacted by the legislature, it will not come into force until a date to be determined by the Lieutenant Governor in Council. That has not yet happened, meaning the provision is not in force and its requirements are not legally binding. The same is true of section 12.5 of the Consumer Reporting Act which creates an obligation for credit reporting agencies to provide consumers with information about the Security Freeze procedure.
We regret publishing information about security freezes based on our false assumption that the provision was already in force, when it was not.
We apologize to the Landlord Credit Bureau for this error. We also apologize to readers and tenants who may have relied on our posts, not realizing that the security freeze provisions are not in force.
To be clear, the security freeze provisions are not currently in force and are not legally binding. The Landlord Credit Bureau by definition has not violated these provisions because they are not in force.