Comments of the

National Consumer Law Center (On behalf of its Low-Income Clients)
Consumer Action
Consumers Union
Consumer Federation of America
National Association of Consumer Advocates
National Community Reinvestment Coalition
Sargent Shriver National Center on Poverty Law
U.S. Public Interest Research Group

Regarding
Notice of Proposed Rulemaking
Free Annual File Disclosures, Rule No. R411005
Amendments to Prevent Deceptive Marketing of Credit Reports
Federal Trade Commission
16 CFR Part 610
RIN 3084-AA94
December 7, 2009

We commend the FTC for issuing the proposed rule, much of which we strongly support. We also appreciate that the FTC is proposing to amend the Free Annual File Disclosures Rule to minimize confusion and exploitation of consumers attempting to access to their free annual credit report. We also commend the FTC for recognizing that
consumer reporting agencies (CRAs) use deceptive and confusing advertising to trick consumers into purchasing goods or services – such as credit monitoring services – that the consumers were not intending to buy. The proposed amendments are a good first cut at restricting abusive advertising practices and we generally support them. We offer the following comments.