National Association of Mutual Companies
16 CFR Part 660, Interagency Advance Notice of Proposed Rulemaking: Guidelines for Furnishers of Information to Consumer Reporting Agencies
Attached are the comments of the National Association of Mutual Companies ("NAMIC") in response to request for comment on Project R611017, "Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies under Section 312 of the Fair and Accurate Transactions Act." NAMIC notes the significant differences between insurance and other financial services products and urges the agency to provide appropriate flexibility in responding to consumer disputes. NAMIC also urges the agency to exempt insurance products from any requirement to furnish account opening dates.