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.

Who Is Using Your Checkbook? FDIC Warns About Qchex.com


While many consumers are scrambling to reduce their risk of identity theft, one business appears to be making it easier than ever to forge checks. Qchex.com allows customers to create checks without verifying the account holder's identity, according to authorities.

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.

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.

Financial Literacy and Education Campaign Strategies


Financial literacy should start early. Fundamental concepts such as the need for savings should be started in elementary school and be carried through the educational process.

Unfortunately, dysfunctional concepts such as “easy credit” are often instilled as college-age students are lured with multiple credit card offers and as television advertisements portray “the good life” as being fueled with credit card accounts. With the average household credit card indebtedness estimated at $9,000, these messages need to be countered early on with education about the responsible uses of credit.

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 on FACTA Disposal Rule: Disposal of Consumer Report Information and Records


The Disposal Rule, as proposed, covers a wide array of entities that compile and use consumer data. Once finalized, the Rule will impose records disposal requirements on entities that before had no reason to consider the consequences of irresponsible information handling practices.

Comments Regarding the Use of Personal Medical Data by Financial Institutions


The proposed rule generally prohibits a creditor from obtaining and using medical information for making decisions about a consumer's credit eligibility. The rule then makes an exception that allows creditors to obtain and use financial information that happens to be related to medical debts, expenses and income.

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