Prohibit Debt Collectors from Calling Cell Phones: Comments to the FCC

The Privacy Rights Clearinghouse (PRC)1 appreciates the opportunity to comment, opposing ACA International's (ACA)2 Petition. The ACA asks the Federal Communications Commission (FCC or Commission) to exempt debt collectors from cell phone privacy rules adopted under the Telephone Consumer Protection Act (TCPA).3 We urge the Commission to deny this Petition.

Comments to the Federal Communications Commission Regarding Implementation of The Junk Fax Prevention Act of 2005

Fifteen years ago when Congress passed the Telephone Consumer Protection Act of 1991 (TCPA), it made what seemed an unambiguous declaration: Unsolicited advertisements to fax machines were prohibited without the recipient's prior express permission. Clear though it sounds, the public's efforts to stop unwanted fax solicitations have had a long and tortuous history. The Junk Fax Prevention Act of 2005 creates a loophole that will surely reverse even the modest progress made against unwanted junk faxes.

Comments on FACTA Disposal Rule, RIN 3064-AC77: Fair and Accurate Credit Transaction Act Disposal of Consumer Report Information and Records

Irresponsible handling of sensitive consumer data has long been cited as a contributing factor to identity theft. A practice known as "dumpster diving" is often claimed by thieves themselves as the source of the data that allowed them to commit the crime. Sensitive data discarded by a financial institution provides a prime opportunity for a crook to access another's personal data.

By enacting §216 requiring proper disposal of consumer information, Congress has given the public one of the strongest tools yet in combating the growing crime of identity theft. It is now up to the financial regulators and the FTC to carry out Congress' intent by adopting strong regulations to ensure identity theft is no longer fed by careless and irresponsible disposal of confidential consumer data.

Comments to Federal Agencies Regarding the Use of Personal Medical Data by Financial Institutions

When it comes to privacy, consumer expectations and fears are most elevated for sensitive data included in medical records. A major concern is potential secondary uses of medical information. For example, a consumer may understandably be concerned that a medical condition could adversely affect the ability to get a job or a mortgage. In recent amendments to the Fair Credit Reporting Act (FCRA), Congress acted to address the discriminatory use of medical information in credit transactions.

Privacy Groups Urge Federal Reserve Board to Protect Consumers from Identity Theft and Stolen Convenience Checks

As the Board is well aware, identity theft is the fastest growing crime in America. The Federal Trade Commission (FTC) estimates that identity theft claims nearly 10 million victims annually, costing millions to consumers and business alike. Significantly, a high percentage of identity theft complaints involve fraudulent use of open-end (revolving) credit products, particularly credit cards. Unsolicited credit products such as convenience checks and activated cards sent through the mail create opportunities for theft. For this reason, we limit our comments here to questions posed by the Board that have broad implications for victims of identity theft.

Comments to the FTC on Accuracy in Background Checks and Insurance Reports

The FTC should separately undertake a review of inaccuracies in employment reports and insurance claims reports.  From our experience, job applicants and employees encounter significant problems when an erroneous criminal history is reported to an employer. Local, state and federal court records are public records that are available to anyone and are not compiled for the purpose of furnishing data to consumer reporting agencies.

Errors in Employment Background Checks: Harmful Long-Term Consequences for Individuals

It is clear to the PRC that the problems of flawed background checks is not new to the FTC. It is also our belief that this is a critical area of consumer protection that deserves the increased attention of the FTC. Our analysis of FTC data uncovered numerous instances of complaints against the same company for reporting inaccurate data, often concerning criminal activities; failure to follow FCRA requirements for limiting information reported; and difficulty in getting the misinformation corrected.

Groups Ask FTC to Stop Blocking Links to Free Credit Report Site, www.annualcreditreport.com

While a number of issues regarding www.annualcreditreport.com need to be corrected, one issue stands out as critically important to correct immediately. That is, the active blocking of Web linking to the annualcreditreport.com site is harming consumers right now, and does not serve any apparent purpose other than to direct consumers to for-pay services at the credit bureaus.

Fair and Reasonable Fee for Credit Score Disclosure: Comments to Federal Trade Commission

For years lenders have relied on scoring models to evaluate risk in extending credit to individual consumers for a car loan, mortgage or credit card. Following the lead of states like California and Colorado, Congress amended the FCRA with the Fair and Accurate Credit Reporting Act of 2003, Pub. L. 108-159, (FACTA), and gave consumers the right to view their score as well as get an explanation of the factors that went into the score.

When consumer interests are factored in, the only fair and reasonable approach is for the Commission to set a fee limited to the actual cost of producing and delivering the score to consumers.

“Pay As You Drive” Automobile Insurance: Recommendations for Guarding Personal Privacy

Along with the potential good to come from reduced driving through PAYD insurance, there is a real risk that insurers will base attractive premiums on consumers’ willingness to accept onboard devices that record much more than miles traveled. Depending on the technology used, devices installed on personal automobiles may track speed, location, duration of a trip, acceleration and deceleration, time of day the trip was made, the identity of the driver, use of mobile phones and more. Once installed, a device originally set to track one driving element may be altered to add additional functions.

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