Comment Number: 522110-00028
Received: 5/3/2006 5:13:00 PM
Organization: First Banc Mortgage
Commenter: Ted Chagaris
State: OH
Subject: Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies
Title: Advance Notice of Proposed Rulemaking
CFR Citation: 16 CFR Parts 660 and 661
No Attachments

Comments:

In reviewing the FICO credit reports from the 3 major credit reporting agencies for my clients;for the intended purpose of residential financing,5 different financial institutions have repeatedly reported inaccurate information.What these orginizations do is report the "high credit limit" of these individuals as LESS than the limit then they actually have. This inaccurate reporting seems as though it is not of a critical nature,but the credit agencies reduce credit scores as the % of credit used approaches 100% and above;sometimes substantionally. For example John Doe has a credit limit of $1000 but the financial institution is reporting a credit limit of $600. John Doe owes $605.His overall credit score is reduced by 15-35 points because it appears that he has exceeded his credit limit(100%+)

The following companies are repeatedly guilty of this type of error:

Capital One

AmeriQuest Mortgage

Beneficial Finance (HFC)

Household Finance (HFC)

In my 3.5 years of serving as a licensed loan officer,I have seen this error in 2-3% of the thosands of credit reports that I have reviewed.