|Received:||5/18/2006 3:19:00 PM|
|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|
Comments:As a consumer, most recently becoming familiar with / aware of the law. my
a) Credit-reporting agencies should not offer a "score" similar to the FICO score.
This is misleading and far too often 100 +/- points different from the actual FICO
score (only available directly from FICO). The consumer often incurs a fee for
the ?fake score? from any of the three nationally know major reporting agencies.
As an example, on Experian?s website they define ?credit score? for consumers,
but nowhere mention that a FICO is the industry standard and that major
variances in their own ?score? and a true FICO number will occur.
b) ANY credit-reporting agency, when asked by a consumer, should be required
to provide access to the consumer's FULL credit FILE. This should include
information from the very beginning, or start of, the consumer's credit file -
regardless of the information?s or contents age (if the consumer's file is 1 year old
or 30 + years old). This is the "consumer's file" and every detail know to the
credit-reporting agency should be given to the consumer if so requested. This
should include "suppressed", "hidden" or ?blocked? information. A reasonable fee
may be applicable in this situation.
c) The credit reporting agencies should not determine whether "a furnisher of
information" (i.e., a bank, credit card company, any entity that has extended
credit, etc.) has policies and procedures in place for accuracy and integrity. This
responsibility must be lie solely on the furnisher of such information to the credit-
reporting agency(s) that they subscribe and report to. I believe that this would
result in abuse of power by the credit reporting agencies and the consumer would
consequently suffer. Perhaps a set of mandatory fields that are regularly provided
and updated on credit reports by the information furnishers should be established
in lieu of this. This may assist in the instance where only negative information in
furnished in regards to a consumer. The reporting-agency should remain just that ?
a reporting agency.
d) It is my opinion that the dispute process should NOT only be with the furnisher
of information, but also involve the credit-reporting agency. It is not always the
most expeditious avenue to dispute with the furnisher.
e) It is my opinion that the credit reporting agencies (most specifically Experian)
have the opportunity to profit greatly in supplying / sharing consumer information
to outside sources and I firmly believe that this skews the agencies? view in
regards to consumers and could be considered a conflict of interest. Credit-
reporting agencies should be prohibited from supplying consumers? information to
outside sources for marketing purposes. There are, by far, many other avenues
for businesses to obtain such information without contacting a credit-reporting
f) Reporting credit limits should be mandatory and not optional for a furnisher or
entity that extends credit. This field is known to be a factor in calculating a
consumer?s FICO score.
g) The timelines for investigation regarding a dispute using a ?free? credit report
and a credit report purchased by a consumer should be identical.
h) A reconsideration of the 7-10 reporting length for an adverse trade-line or
insertion of judgment / bankruptcy should be performed. Is this length of time
unreasonable punishment upon a consumer, is it necessary and for what true
purpose given today?s technological information avenues?
i) Attention should be drawn to the agreements between the credit-reporting
agencies and the furnishers of information in respect to ?deleting? a file. It must be
stressed, above all, to the credit-reporting agencies that reporting a trade-line is
not mandatory, but optional. If the consumer account, or a detail thereof, is being
reported erroneously, the furnisher of the information (creditor) must have the
option and ability to delete, or stop reporting the erroneous information ?
superseding any agreement between the credit-reporting agency and the furnisher
of the information that may disallow this function or ability.
j) In the instance of a consumer account that is placed with a third party or
collection agency (that subscribe and submit to the credit-reporting agencies), the
original creditor should have the ultimate responsibility for the accuracy of
information supplied to a credit-reporting agency. In the instance where an
account is placed with a third party, internal collections, or outside collection
agency - re-aging becomes an issue during this period - especially with
companies knows as ?junk debt buyers? ? this predatory practice needs to be