|Received:||3/23/2004 8:00:00 AM|
|Agency:||Federal Trade Commission|
|Rule:||FACTA Free Reports Proposed Rule|
It is a good idea to allow consumers to receive annually the information contained in their credit file. In reading the proposal for roll-out, I would make two comments. First is that the roll-out could be done on a monthly rather than quarterly basis, but still by states. Although this would increase the number of distribution dates, the idea of advertising on a geographic basis by state would still allow measured impact on the centralized agency. Increasing the number of distribution dates would decrease the deluge of a quarterly roll-out. Since a new centralized agency would not have any track record, a gradual implementation with a few states in the first month would allow the system to work out the bugs. Spreading the 50 states out over 12 distribution times would allow for less "busy signals" as suggested in the comment invitation. It would still be manageable and very receptive to a national advertising campaign, done by state (not birthday or other denominator). Too many people would be discouraged if they have to call back once or several times (most likely if you have only three distribution times) to obtain the information. Better control would be realized if the distribution was done over 12 periods, with prescribed states (still by geographic grouping) assigned to respective calendar months. this gradual implementation would much more evenly distribute the impact and still be easily understood by the general public (who understand this type of segmented distribution from driver's licenses and vehicle registrations, among other things). Secondly, I believe the information released by the CRA report should include the credit score that is assigned by the agencies (all three if not uniform by that time). This is important information that is very much a part of the credit record, but it has been suggested in the invitation to comment as being supplemental and could be available by additional request - and therefore at an additional charge - from the central or individual CRA. Credit scores are an integral part of the credit record, as it would be similar to giving out grades in school without the Grade Point Average. GPA is the final determinant, just as the Credit Score is the final analysis of the credit record. While the primary objective of the credit report distribution was to prevent fraud and identity theft, the credit score is and should be part of any distribution of information, so that consumers can see the results of their record. Having the base information is of little or no value to the consumer if they cannot determine what it means in application in the financial world. This is especially important if all three CRAs evaluate the record in different ways. Thank you for the opportunity to comment.