|Commenter:||Dr. James Matey|
|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 a sophisticated computer user. I have designed and built web pages as part of my professional duties. I routinely construct and test computer programs. I have a PhD in Physics and more than 30 years of experience in the use of computers. I have 5 computers in my study running various applications and operating systems. The process (on the credit bureau sites to which we are referred by the annual report site) for getting a free credit report seems to be intentionally constructed to be confusing so as to induce the user to inadvertently subscribe to a automatically renewing service that they would likely not want and almost certainly do not need. I got my report from Experian today. After two tries. On the first try, despite care on my part, I ended up at a point where, if I had pressed the button, I would be signing up for a service that would be charged automatically each year to my credit card, for life, unless I went back and cancelled. If a sophisticated user can be misled, what about less sophisticated users ? Of course that is precisely what I suspect the credit bureaus want -- the cost of providing the service is likely essentially zero, the fee they charge is likely nearly pure profit. If they only induce a small fraction of the people inquiring into this error, they get a large return. In round numbers, if 10% of the public with cards (say 100 million) make queries and 10% of them make the mistake, the profit could be )0.1*0.1*100 million * $30 = $30 million/year. You can judge whether these guestimates are too low. The link from the main annual report page should NOT LINK to anything except the free report. I would be willing to concede a single link of the form "FOR ADDITIONAL SERVICES FOR WHICH YOU WILL BE CHARGED, PRESS THIS BUTTON". This button could take the user to whatever page the credit bureau wants. There should be absolutely NO INTERWEAVING between the free report and any other service. There should be NO ADVERTISING on the free report pages.