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 consumer, I strongly support the proposed amendment to the Federal Trade Commission's Free Annual File Disclosures Rule, 16 CFR Part 610. Your current regulation is very weak at protecting consumers from fraud and scams associated with "free credit reports" that, in fact, are not free at all and carry many hidden costs far greater even than a monthly charge to a credit card for a product or service consumers have not knowingly ordered. Anything you can do to prohibit practices that interfere with the free file disclosure process would be very welcome. If anything, your proposed amendment does not do nearly enough to adequately protect consumers from fraud and scams concerning so-called "free" offers that are not free at all. Even what you call "prominent" disclosures might not be adequate to keep consumers from being confused about and scammed by these "free" offers that actually carry fees or charges with them, often recurring in nature, which can lead to hefty payments. Dishonest companies will find a way around these disclosures too and will keep deceiving unsuspecting consumers who are just interested in obtaining their federally mandated free annual file disclosures without a lot of hassles. Even delaying advertisements for products or services until after consumers receive their free annual file disclosure will not keep dishonest companies from scamming consumers. These dishonest companies will just find even more creative ways to defraud consumers who are simply seeking truly free, federally mandated credit reports. Therefore, I would like to see an even stronger amendment to your rule. This stronger amendment would prohibit advertisements of any sort for these deceptive "free credit report" offers to be included with, or associated in any way with, the federally mandated free annual file disclosures available through the single centralized source. You should also force these dishonest companies to refund all the millions of dollars they have scammed from unsuspecting consumers as well as fine these companies heavily and put them out of business.