Submission Number: 00002
Received: 3/15/2011 10:12:49 PM
Commenter: Terry Katzur
Organization: ELGA Credit Union
Agency: Federal Trade Commission
Initiative: Board of Governors of the Federal Reserve System (Board) and Federal Trade Commission (Commission) FCRA Risk-Based Pricing Rule Amendments;
Attachments: No Attachments
The changes to the RBPN seem unnecessary and redundant. The last I checked the proposed additions to the RBPN are already contained on the credit report, which every consumer can obtain for free through the credit bureaus if they choose to educate themselves about their credit.
More than anything the proposed changes are an inconvenience. Every time we are forced to add additional notices or amend existing notices it uses resources that could otherwise be used to better serve our members. Providing information that is already available from other sources is inefficient.
This change in itself will not have a major impact on most financial institutions but why add additional unnecessary demands to an already burdensome regulatory environment. Small institutions are straining under the weight of the ever changing regulatory environment.
These small institutions serve the underserved. They are often in small communities serving members, employing citizens, and providing a service that larger institutions will not. To continue adding redundant and unnecessary demands puts further stress on the already thin margins of many institutions and limits their ability to serve their members.
The current RBPN already requires the contact information for the credit bureaus. Consumers, if interested, already have all the information they need in order to obtain their credit information.
Please reeavaluate the proposed RBPN changes.