16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures #545091-00277

Submission Number:
545091-00277
Commenter:
Stephen Fisher
State:
IL
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

To prevent deceptive marketing of credit reports: All sites advertising free credit reports should on their landing page provide a direct link to the facilities to download the free report. The site should be prohibited from collecting any personal information that does not directly feed downloading the free report to prevent site owners from tricking consumers into providing personal information that does not lead directly to a free report. Once the user has downloaded the free report the site owner should expunge all personal information provided by the user unless the user indicates by means of a direct response such as a click on a web badge or other marker that they wish to explore a commercial offer made by the site. All credit bureau advertising, upsells and "sponsored links" should also be prohibited from appearing on the landing page and all subsequent pages required to download the free report. Advertising or credit bureau offers should be allowed only after the user has made a final selection to download the report. Finally, it should take no move that than two mouse clicks from the landing page to deliver the free report.