16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures
The rule should specifically prohibit the use of the phrase "free credit report" that does not comply with the definition in section 610.4(a) of this rule in any advertisement for other products and services. Use of the phrase "free credit report" in product or service advertisements where the phrase is not consistent with the definition in this rule is misleading to consumers. This phrase is significant to consumers only because of the legislation providing them access to their reports and should be limited to that purpose, not as an inducement to purchase other products and services. The definition of "free credit report" in section 610.4(a) includes the phrase, "... that is, in any way, tied to the purchase of a product or service." This phrase begs the clarification of the word "tied" as used in this context. The concern to be addressed is the commitment of a consumer to purchase or consider the purchase of a product(s) or service(s). Thank you for the opportunity to comment.