The Fair Credit Reporting Act (FCRA) requires nationwide specialty consumer reporting agencies (NSCRAs) to provide, upon request of a consumer, a free annual disclosure of the consumer’s file, commonly known as a consumer report. The FCRA’s implementing Regulation (Regulation V) includes a rule mandated by the FCRA that requires each NSCRA to establish a “streamlined process for consumers to request [their free annual] consumer reports . . . which shall include, at a minimum, the establishment by each such agency of a toll-free telephone number for such requests.” 15 U.S.C. § 1681j; 12 C.F.R. § 1022.137.