|Organization:||Community Legal Services of Arizona|
|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:I am responsible for heading the Statewide Consumer Project. The SCP advocates on behalf of low income consumers in Arizona on a broad range of issues. The "free credit" report industry targets the most economically vulnerable consumers in our State and provides nothing in return of value that the consumers can not obtain for free from the credit reporting agencies. In my experience, this industry has no more utility to consumers than pay day loans and debt consolidation companies which also prey on the economically vulnerable and legally naive. Like payday lenders and debt consolidation companies, the "free" credit report companies provide nothing worthwhile in exchange for outrageous fees our clients can ill afford. I urge the strongest possible regulation reining in the abuse of this industry.