16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures #545091-01016

Submission Number:
545091-01016
Commenter:
Professor Richard Alderman
Organization:
University fo Houston Center for Consumer Law
State:
TX
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

As a law professor, Director of the Center for Consumer Law, and a TV personalty with a consumer news letter, I have encountered hundreds of people mislead by these ads. It seems the solution is simple, you may not use the word free if there are any strings attached. In legal terms, "the word free may not be used in connection with an offer for a credit report unless the report is provided to the consumer at no charge, with no additional agreement, express or implied, absolute or contingent, to purchase, lease, or review, any additional goods or services." I see no reason to allow any other use of the word free in connection with a credit report.