February 25, 2008
Federal Trade Commission
Office of the Secretary
Room H-135 (Annex K)
600 Pennsylvania Avenue, NW
Washington, DC 20580
RE: CREDIT REPORT FREEZES―COMMENT, PROJECT NO. P075420
To Whom It May Concern:
Consumers Union , the non-profit publisher of Consumer Reports® submits these comments on behalf of ourselves, the Privacy Rights Clearinghouse, and the National Consumer Law Center (on behalf of its low-income clients) in response to the Federal Trade Commission’s inquiry regarding the impact and effectiveness of credit report freezes (security freezes).
In summary, we offer the following overarching comments and recommendations:
o Consumer demand for the security freeze is strong; the most effective state models meet that demand by providing affordable, accessible and convenient security freeze rights to all consumers.
o The Commission should be vigilant in ensuring that consumers are receiving accurate and complete information from consumer reporting agencies about their security freeze rights. The Commission should also monitor CRAs and other vendors of identity theft prevention tools to ensure that marketing of ID-theft prevention packages that include the freeze do not, by misrepresentation or omission, mislead consumers about their freeze rights or the commercial products offered.
o The Commission should study the viability of an effective, convenient and secure one-stop shopping mechanism for placement and temporarily lifting of the freeze.
o The Commission should launch a consumer education effort to promote improved consumer understanding of the security freeze and clarify differences between the security freeze and the fraud alert.
o Federal legislation is important in providing for nationwide freeze rights, but must not preempt state laws providing more convenient, accessible and affordable freeze rights.
For the full comments, click here (PDF format).