|Commenter:||K. R. Morris|
|Agency:||Federal Trade Commission|
|Rule:||16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures|
Comments:Requiring ads for sites that are not the centralized free access site to carry prominent notice that they are advertising a for-profit site is a good idea. However, the word "prominent" should be clarified as much as possible, as the advertisers are likely to interpret it to their advantage. Delaying ads on the centralized site is better than running ads throughout the steps of submitting a request. However, if access to credit reports is actually FREE, there should be NO opportunity for the credit bureaus to advertise at any point during the process of requesting a FREE report. Disallowing ads would eliminate any consumer confusion or error. The credit bureaus still make money from vendors accessing credit reports and from selling credit scores, which (ridiculously enough) are not included on the free credit reports. They will not go out of business just because they lose the opportunity to advertise at any point during a consumer's report request! Thank you.