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INTRODUCTION A credit report in the United States is like a digital shadow: a picture of who you really are, following you everywhere you go. Trying to get a job? [...], In the many decades following World War II, America has become a country run on credit. Hardly a day passes in which the average citizen has not been offered a new credit card, loan, or opportunity to refinance their existing debt. Underpinning it all is a vast credit ecosystem processing incredible amounts of data. When Congress passed the Fair Credit Reporting Act, it attempted to establish rules of the road to protect the hundreds of millions of citizens interacting with this ecosystem every day. The federal government, as the nation's largest employer and purveyor of student financial aid, is a massive player in the credit ecosystem. But what happens when a citizen tries to hold the federal government accountable when it breaks the rules governing this ecosystem? As it turns out, results vary depending on where the plaintiff resides. In the 2019 case Robinson v. United States Department of Education, the Fourth Circuit considered whether the definition of "person" in the Fair Credit Reporting Act created a waiver of sovereign immunity. Ultimately, the Robinson court, agreeing with the Ninth Circuit, determined that the answer to this question was no, denying plaintiffs access to the civil enforcement provisions of [section][section] 1681n-o. However, the Seventh Circuit continues to hold such a waiver did occur. When provided the opportunity to settle the issue once and for all, the Supreme Court denied certiorari. This Recent Development argues that the Supreme Court should have resolved the circuit split by granting certiorari to overrule Seventh Circuit decisions contrary to precedent. Further, it argues the Fourth Circuit failed to appreciate that its ruling, combined with state sovereign immunity, absolves all "governments" from the Fair Credit Reporting Act's enforcement provisions. The Fair Credit Reporting Act was meant to protect citizens from the consequences of unscrupulous actors in the credit ecosystem, the federal government being one such actor. While the reasoning against a waiver of sovereign immunity is sound, these outcomes cannot be reconciled with why the Act was conceived. This Recent Development concludes by advocating for a congressional amendment to the Fair Credit Reporting Act. The addition of an explicit waiver of sovereign immunity to [section] 1681n is necessary to ensure the Act's desired deterrent effect. Because it may be some time before the Supreme Court has an opportunity to address the matter again, this Recent Development calls upon Congress to amend the Act to ensure its continued vitality by clearly stating that willful violations of the Act entitle injured individuals to sue the federal government. Congress should do so through an even more explicit waiver of sovereign immunity, using the "magic words" that the Fourth and Ninth Circuits so desperately desire: "United States." Such changes may be the only way to ensure one of the biggest players in the game abides by the rules.

After the global financial crisis in 2008, a new form of shadow banking emerges rapidly in China. Non-financial state-owned enterprises (SOEs) re-lend the low cost funds they obtain from state-owned banks to private enterprises through entrusted loans and direct lending. The rise of such shadow banking activities is rooted in China's long-standing incomplete financial system. This paper introduces a two-sector overlapping generations model to study the dynamic effect of the re-lending activities on resource allocation and economic growth. The quantitative results show that in the short run, shadow banking activities as an alternative financing channel for private enterprises improve resource allocation efficiency, although in the long run they reduce economic growth. Therefore, the re-lending of SOEs cannot simply be killed with one stick. The regulation should be accompanied by a series of supporting reforms to facilitate financing in the private sector and dynamically improve the efficiency of resource allocation. Keywords: Shadow Banking, Resource Allocation, Financial Constraint, Financial Regulation, I. Introduction The emergence of shadow banking has become a striking phenomenon in the financial market in China since 2008. The scale of shadow banking activities varies with its definition. [...]