16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures #545091-00213

Submission Number:
545091-00213
Commenter:
Dr. Greg Brailsford
State:
RI
Initiative Name:
16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures

Regarding the proposed rule changes for the Annual Credit Report program, I agree with the changes. However, I do think it is sketchy to require other companies to put disclaimers on their site saying they are not the annual credit report site. Now, to touch on that whole freecreditreport.com confusion problem - the issue stems from the fact that it is not a free credit report. You have to sign up for their credit monitoring service. The whole "free [whatever]" concept in advertising is so out of whack now it has become absurd. Companies should be prohibited from advertising anything that is free if you are required to purchase or sign up for anything that is NOT free - regardless of whether there is a free trial. Companies should be required to word their ads so that the gimmick and the catch are mentioned together and given equal billing: "Free credit report when you sign up for [monitoring service]." Instead, companies like freecreditreport.com are allowed to run TV ads that advertise something free with just a 2 second blurb "applies with enrollment in triple advantage". Well, what IS triple advantage? If that is what you are really advertising, why is the ad 99% devoted to the free gimmick?? It is misrepresentation. Companies need to stop using tricks and misrepresentation in their advertising. If your product is something nobody wants, then go create a product they do want - don't hide it behind a free gimmick.