|Received:||12/21/2004 9:36:11 AM|
|Agency:||Federal Trade Commission|
|Rule:||Advance Notice of Proposed Rulemaking, Request for Comment|
|Docket ID:||RIN 3084-AA94|
Comments:Credit SCORES are the wrong place to be focusing energy. Credit scores are only a red/yellow/green indicator - a convenience, not sufficient to determine WHY someone's credit is what it is. Drop the emphasis on credit scores. Focus entirely on forcing all credit bureaus to provide, AUTOMATICALLY, FOR FREE, ON A DAILY BASIS notice to every individual on whom they keep records, of the full details of every inquiry in to and update to that individual's credit file. It is this timely notice of inquiries and updates which makes it possible for individuals to respond quickly enough to identity theft indicators. Nothing else is sufficient. Credit bureaus make money by accumulating information about private citizens without those citizens knowledge or approval. It is immoral for these same credit bureaus to faciliate identity theft through shoddy privacy practices while at the same time demanding payment from the individuals whose data they hold in order for those individuals to receive timely notice of events of direct concern to those individuals. To repeat: what is truly needed is for all credit bureaus to be required by law to provide immediate notice to every individual about whom the credit bureaus hold data, of every inquiry in to and update submitted to each individual's credit file. Only this is right (being that the individual is the source and should be the owner of the data on which the credit bureaus trade and make money) and effective in catching identity theft early enough to stop damage.