16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures #545091-01109

Submission Number:
Mr. Alex Crisafulli
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
1) The FTC should threaten to initiate a criminal investigation into the behavior of the credit reporting agencies regarding this program - with the ultimate goal being an out of court settlement that prevents any of the three from offering or promoting any kind of credit monitoring service. Concurrently, any credit monitoring service would be prohibited from offering a "free" credit report from the three credit reporting agencies to an individual consumer within the context of this program. An individual would have to order the report directly by himself, and any third party would have to pay the credit agencies a reasonable fee for obtaining a report on behalf of someone else, could not represent such products as "free", and the consumer would still be entitled to an actual free report within the year in question independent of whatever report a credit monitoring service obtained for him. This would prevent conflicts of interest as well as the endless (and I mean ENDLESS) looping of offers that a consumer presently goes through before finally deciding that he will not obtain a report without paying for it. The way the credit reporting agencies frustrate any attempt (even the most persistent and intelligent ones) from succeeding through such tactics as feigned "confusion" regarding whether consumers are ordering a "free report" or "a paid credit monitoring service" is not innocent - it is a willful violation of their legal obligation to provide these reports to help consumers guard themselves against identity theft. 2) The credit reporting agencies should be required to have at least some sort of live phone support for handling early (or even initial) rejections of requests. This would incentivize them to provide the reports more readily because it would be less expensive for them to simply provide the reports in the first place than it would be to pay people to handle disputes regarding their failure to do so. There should be no shredding of documents submitted by applicants until either the report is furnished or the dispute resolution is completed. This would prevent bogus denial of applications under the guise of "illegible documentation" and so forth. Proof of one's identity should be requested on the first form submitted (as opposed to being requested via a second submission as an unnecessary second step after what amounts to be an initial automatic rejection). Only a settlement which leaves the credit reporting agencies no wiggle room will solve these problems - in other words, which eliminates the credit reporting agencies' conflicts of interest with those entities which monitor consumers' credit for a fee, and which makes it in their self-interests to readily provide the reports rather than continue to willfully frustrate consumers' attempts to obtain them. Attached are complaints I made to the FTC regarding TransUnion and Equifax. They are indicative of what has occurred in some variation every time I have made a credit report request from all three agencies - at a great expense of aggravation and time. I can be contacted by telephone or e-mail for more information or documentation regarding this matter.