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.

FTC Disposal Rule: Does it Apply to You?

The goal of the Disposal Rule is to reduce identity theft and other fraud through greater protection of consumer information. The rule applies to consumer reporting agencies like credit bureaus, employment or tenant screening companies, as well as companies that compile information and sell reports on medical history, check writing history and insurance claims. Significantly, the Disposal Rule also applies to any business that uses such reports.

FTC Sues Imposter Web Sites Offering "Free Credit Reports"

The FTC this week announced a lawsuit and simultaneous settlement with Consumerinfo.com, a subsidiary of the credit bureau Experian, and freecreditreport.com, companies that advertise free credit reports. The FTC charged the companies with "deceptive and misleading" claims.

Consumerinfo.com and freecreditreport.com advertised "free credit reports," but failed to inform consumers that they were automatically signing up for credit report monitoring services and would be charged $79.95 if they did not cancel within 30 days.

Comments Regarding Federal Trade Commission Proposal to Continue to Conduct Surveys of the Public on Identity Theft

The Commission's 2003 survey found approximately 10 million identify theft victims in the prior year. Before the 2003 survey was released, annual victims were estimated at between half to three quarters of a million per year. These earlier estimates, everyone with any knowledge agree, grossly underestimated the scale and impact of this crime. The 2003 survey sounded a wake-up call. Still, we are not convinced that a complete picture of identity theft is known.

New Look for Prescreened Credit and Insurance Offers

tarting August 1, 2005, unsolicited offers for credit or insurance that are based on information in your credit report should be easier to spot.

New regulations adopted by the Federal Trade Commission now require notices to prominently display the toll free number (1-888-5OPTOUT or 1-888-567-8688) to opt-out. Now, this number, along with a statement that you can stop the unsolicited offers, must appear - in at least 12-point type - on the first page of the offer.

Comments to the Federal Trade Commission: Prerecorded Telemarketing Calls to Existing Business Customers (EBR)

For years intrusive, privacy invasive telemarketing calls have been a major source of consumer outrage.  Calls made by so-called “predictive” dialers -- automatic dialing that allows a telemarketer to call multiple households at one time -- have been a significant consumer complaint. Such calls are intrusive, invade the privacy of one’s home, and result in great annoyance when one races to answer the phone to find only dead air or a hang-up on the other end of the line. Predicative dialer calls are particularly troublesome and potentially dangerous for the elderly and the disabled.

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