Evergreen Credit Reporting, Inc.
16 CFR Part 610 Amendments to Rule to Prevent Deceptive Marketing of Credit Reports and to Ensure Access to Free Annual File Disclosures
Dear Federal Trade Commission, I own Evergreen Credit Reporting, Inc., a credit reporting company that operates the web site www.CreditReporting.com. Creditreporting.com offers credit report products for sale to consumers and offers "free credit reports" to consumers in connection with a credit monitoring trial offer. In addition, Creditreporting.com offers extensive information and content for consumers about credit reports and credit reporting topics including several web pages (and a video) about how consumers can get their credit reports free under law. We do not attempt to mislead consumers, but we do generate revenue for our company by selling credit reports and related products to consumers, and we are sensitive to FTC requirements that may adversely affect our ability to sell legitimate products. That said, we fully support the FTC in requiring that advertised offers of "free credit reports" have full disclosure that the products are not the "free credit reports" available under law. Furthermore, we support additional FTC approved language in the required disclosure that gives important details about such "free credit report" offers including specifics about the eventual cost, duration of the free trial, etc. In all such cases, the consumer should be protected from unlawful or false and misleading advertising claims. We feel a standardized disclosure from the FTC will solve this problem, and we await your preferred language. However, one requirement in particular that the FTC is suggesting seems extreme. I am speaking specifically about proposed section 610.4(d) (4) - Disclosure for Internet websites. The requirement for Internet websites to display a separate landing page with the FTC's proposed disclosure and proposed hyperlink structure goes way beyond what is necessary to sufficiently inform the consumer that the product being offered is not the "free annual credit report" available under law. Displaying a standardized disclosure approved by the FTC on the web page with the "free credit report" offer will be sufficient to inform consumers about their rights. It is just not necessary to serve a separate landing page to avoid misleading the consumer, and to require the separate landing page proposed by the FTC unfairly encumbers the credit monitoring industry that relies on "free credit report" advertising to get customers to try the monitoring service. The main problem with a separate landing page is I think it will direct most if not all the potential monitoring customers to the central site whether the consumer is looking for the free annual credit report under law or not. That is a costly problem for those of us who offer monitoring services as attracting visitors to your site on the Internet costs lots of money. As far as the rest of your proposed rule, I have always felt the centralized site should not be used by the three credit bureaus as a forum to market their products and gather customer information. Therefore, I will always object to allowing the three credit bureaus to market other products through the centralized site. Moreover, I do not think credit bureaus should be allowed to market to users of the centralized site after the fact without implicit opt-in procedures in favor of the consumer. In summary, please do not implement the separate landing page requirement, only require better and more prominent disclosure messages to consumers. Additionally please rule that Annualcreditreport.com should be used only to deliver free annual credit reports to consumers and not for marketing any products during and/or after the consumer gets their free credit report. Sincerely, Charles R. Burnett President, Evergreen Credit Reporting, Inc. www.creditreporting.com