|Received:||3/12/2005 10:34:50 PM|
|Agency:||Federal Trade Commission|
|Rule:||Notice of Proposed Study on the Effects of Credit Scores and Credit-based Insurance Scores on the Availability and Affordability of Financial Products|
Comments:Fico scoring models could only be as accurate as the data it uses. Given that the majority of consumers have inaccurate data on their credit files, FICO cannot be a fair representation of the consumer. Their models cannot accurately predict default rate. My ex-husband has a low FICO, however HIS FICO is only 20-30 pts below mine. First, there is nothing joint on the credit reports. Second, he has NO credit cards, loans, mortgages, car installment loans. His credit report is 100% unpaid collections yet he has a FICO of 544. My lowest is 568 with highest 590. I have a mortgage with 2 lates, 2 completely current car notes, 5 credit card tradelines with 100% current listing and 2 credit cards that show 1 30-day each. There are 2 medical collections - 1 of which is NOT related to me or anyone in the household. My ex cannot hold a job. I have a 'good job' and am salaried at over $60K. I have a sibling that has a credit report that reflects $40K in defaulted credit cards and the associated $40K in collections. His scores are in the 550 range! To give each of us the same risk category is LUDICROUS! I have had a CLEAN MVR for 25 years. How could ANYONE state that my driving is related to my credit? This entire scoring model was designed to assess risk. Now it is ABUSED by the credit grantors to inflate interest rates and "annual fees!" They are abusing the consumers LEAST able to afford to pay 29% for a credit card! The most ABUSIVE thing occurring in the banking industry today is the use of Universal Default. The late pays on my accounts were the result of an order by a judge to secure an attorney for my minor child. A ONE time event that cost me a couple of 30-day late payments on 2 cards and my mortgage has caused ALL my credit cards to skyrocket to over 25% each in interest rates! Even the cards where I maintained YEARS of current payment history. This is unfair and unbelievably unamerican. I have reduced the balances on all my credit cards and next month I will pay them off and place them in a drawer to gather dust. The REAL cause of today's Bankruptcies is FICO/Universal Default based most commonly combined with the unregulated medical insurance companies refusing to pay coverable expenses. FICO is invalid and unfair and needs to be eliminated.