| Comment Number: | 522110-00018 |
| Received: | 4/26/2006 8:42:14 PM |
| Organization: | Individual Consumer |
| Commenter: | Charles Ferguson |
| State: | OK |
| Subject: | Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies |
| Title: | Advance Notice of Proposed Rulemaking |
| CFR Citation: | 16 CFR Parts 660 and 661 |
| No Attachments |
Comments:
A friend of the group I belong to wrote me the following, 'Seems to me that the real question is, unless it is stipulated in the fine print of the credit card or other agreement used to provide an extension of credit, the original creditor does not have the authority to share the SS# with a third party Collection Agency, which has to be done in order to get the CA item placed on the credit report. At that point it is not private anymore, is it? I don’t know if this is a loophole or not, but it is an interesting concept that would seem to be “technically” correct. I dunno.' Can it be such that the Government can force Original Creditors to truncate or completely remove debtors Social security numbers prior to selling debts outside the SOL for collection to third party collection agencies. In doing so I would venture to say the majority of false information being submitted to Credit Reorting Agencies by "Furnishers" would drop significantly, plus the instances of Identity theft would also be affected by removal of debtors Social Security numbers prior to selling written off debts to third party collectors ie; "Furnishers". These are the individuals and company's we fight daily in order to correct our credit files. We aren't attorneys but individuals who are dedicated to fighting false and inaccurate information on our Credit Reports. If the Government were to institute strict guidelines in reference to Original Creditors not supplying third party collectors with debtors Social Security numbers and personal Identifying information, the Original Creditor would have a greater role in the fight against false reporting and Identity theft in regard to consumers personal information falling into the wrong hands of individuals not entitled to that information. Afterall there are a couple of steps that lead up to false reporting and Identity theft. Holding the Orignal Creditor liable for removal of personal identifying information from witten off debts that are sold would be a milestone in the fight against false reporting and Identity theft. When we apply and recieve credit and then are unable to pay per the contract and the Orignal Creditor writes off the debt seems that when they sell the written off debt to third party collectors or as I see them "Furnishers" giving or allowing those third part collectors to have personal information that was intended solely as a part of the contract between the Original Creditor and Consumer is like the Original Creditor getting his last licks in against the Consumer by allowing personal Identifying information to be shared, knowing that written off debts are sold over and over again. I agree with my friend that Original Creditors have no authority or viable written permission to give my personal Identitying information to anyone but a Credit Reporting Agency. Has our personal Identitfying information become like names on a caller list, sold to the highest bidder and opening up Consumers to blackmail by third party collectors posing as though they are the Original Creditor we contracted with?