| Comment Number: | 534030-00043 |
| Received: | 2/25/2008 5:59:13 PM |
| Organization: | Evergreen Credit Reporting, Inc. |
| Commenter: | Charles Burnett |
| State: | NV |
| Agency: | Federal Trade Commission |
| Rule: | Credit Report Freezes |
| No Attachments |
Comments:
This response is pursuant to the FTC request for public comments on credit freezes. My company, Evergreen Credit Reporting, Inc., is a consumer reporting agency who operates a web site www.creditreporting.com for consumers to obtain information about credit reports and related topics, as well as to purchase credit report products including merged credit reports, credit scores and credit monitoring services. From our perspective as a credit reporting company which deals with consumers on a daily basis who call us for information about free credit reports, credit scores, identity theft and every other credit related question you can think of, it is evident that one of the most important issues to consumers is reacting to and protecting against identity fraud. In the past the response we give victims or suspected victims of identity fraud includes contacting all three national credit bureaus and putting fraud alerts on their credit reports, reviewing their 3 credit reports for unusual or unauthorized activity, and monitoring their credit reports in the future just in case eventual fraud activity occurs or continues into the future. Perhaps the only reason we do not discuss credit freezes more often with consumers is that the credit freeze process is complicated by different state laws, rules and fees that even we cannot be expected to be understand for every state. Additionally each credit bureau may have different procedures to put a freeze in place. In our opinion we need a unified federal law regarding freezes that functions as easily as the current credit bureau fraud alert procedure that will allow consumers to put initial credit freezes on their credit reports free of charge in the event of suspected or actual identity theft. In our view the consumer should only have to contact one of the bureaus to have all 3 credit report freezes initiated, much like the consumer does today to place a fraud alert on their credit reports at all 3 bureaus. The ability to freeze should also be extended to any consumer who desires it, although we view such elective credit freezes as a choice or tool for the consumer to control access to their credit file. These elective credit freezes should be subject to a reasonable charge paid to the credit bureaus. The subsequent ability to freeze and unfreeze the credit reports should also be subject to reasonable charges from the credit bureaus for the consumer who wishes to exercise such control over his or her credit file. As a result subsequent, elective freeze/unfreeze activity would then be in the control of the consumer as it relates to frequency, duration and indirectly the cost. Sincerely, Charles R. Burnett President Evergreen Credit Reporting, Inc. www.creditreporting.com