“It sure smells like the prescreening provisions of the FCRA,” Reidenberg told The Intercept. “From a functional point of view, what they’re doing is filtering Facebook users on creditworthiness criteria and potentially escaping the application of the FCRA.”

“If Facebook is providing a consumer’s data to be used for the purposes of credit screening by the third party, Facebook would be a credit reporting agency,” Reidenberg explained. “The [FCRA] statute applies when the data ‘is used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumer’s eligibility for … credit.'” If Facebook is providing data about you and your friends that eventually ends up in a corporate credit screening operation, “It’s no different from Equifax providing the data to Chase to determine whether or not to issue a credit card to the consumer,” according to Reidenberg.