What did the court decide in Safeco Insurance Co. of America v. Burr?
Answered for: US
reckless disregard of a requirement of FCRA would qualify as a willful violation within the meaning of § 1681n(a)
The Court held that 'willfully' in the Fair Credit Reporting Act covers reckless violations, not only knowing ones. The sentence above is the court in its own words.
This answer is true in US and nowhere else on this site. Another jurisdiction is another answer, or an honest gap: see what has been read for US.