Comment Number: 522110-00101
Received: 5/19/2006 3:05:00 PM
Organization:
Commenter: Betty Baldwin
State: TX
Subject: Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies
Title: Advance Notice of Proposed Rulemaking
CFR Citation: 16 CFR Parts 660 and 661
No Attachments

Comments:

Errors: Date of last activity on closed,charged off accounts is often updated to
current month making it appear as if the account was used more recently when in
fact the account was closed,charged off years ago. Example: A company who
reported a charged off debt in 8/1999 updates each month to the credit bureau the
date of last activity would show the current month/year.

Omissions: Many times credit limits are not being reported instead they show high
balance as the limit or whatever the balance may be at the time. Someone who
paid off a debt or chooses to keep balances low their credit line would appear to
be $0. This makes it appear that there is no available credit limit or the line of
credit is at its max both would adversly affect credit scores, especially for those
consumers who have very little credit established.


Other:  Debt purchasers who purchase old defaulted debt are reporting charged off,
open ended consumer credit as "Factoring company accounts", creating the false
impression that these are open, late accounts of a completely different character
and legal status.

Some Debt purchasers are instantly reporting debts rather than send initial
communication or any communication to the consumers. This is being done to
bypass the consumers right to dispute and request validation under federal law. 
What happens is consumer sends dispute directly to debt purchaser, debt
purchaser discards dispute/validation request. Consumer disputes with credit
bureaus, debt purchaser verifies to credit bureau without any obligation to cease
collection activity.

Debt purchasers receive written disputes from consumers and then list the
tradeline as information disputed by consumer. In some cases this notation is left
and forgotten. No investigation takes place by the debt purchaser, consumer never
hears back from debt purchaser, there is no resolution to the dispute. A change is
needed here.

Third party collection agencies/Debt purchasers  reporting date opened as the
date they received the account rather than the actual date the account was
originally opened with the original creditor, along with no date of first deliquincy
shown users of credit reports could assume that these defaults are more recent
than what they really are. This kind of poisoning tactic is used quite often to have
more adverse afftect on credit scores.