|Received:||4/3/2005 11:01:30 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:I have subscribed to a credit monitoring service through Equifax for the past two years. In an effort to improve my credit-rating, I haved worked hard and paid down more than 35% of my credit limit-to-balance ratios. Strangely, with no other changes on my credit report beyond the reduction of my balances (limits remained the same), my FICO score as reported by Equifax dropped by 15 points. This seems to me to point to a very arbitrary and capricious system. I paid balances down on the basis of advice from Equifax's "FICO simulator" from a report I received several months ago -- a report that I paid them for. This report indicated that paying down my balances was the best strategy for increasing my FICO score, but has, in fact, lowered my score. In addition, I understand that each CRA has the power to create its own "scoring system", which may or may not be based on a consistent algorithmic model. I believe that it is time for the FTC to do something to regulate the concept of "FICO scoring", especially because it bears so much weight in the day-to-day matters of common consumers. If an individual's ability to obtain housing, transportation, and credit rests on a FICO score, which may be unreliable from CRA to CRA, this score must be regulated and consistent in order to uphold the United States' promise of equality to all. Thank you for considering my comments.