In response to the Consumer Financial Protection Bureau’s (CFPB) Advance Notice of Proposed Rulemaking regarding the Fair Credit Reporting Act (FCRA) and coerced debt, a coalition of organizations, including the National Consumer Law Center (NCLC), the Center for Survivor Agency and Justice (CSAJ), and the National Coerced Debt Working Group (CDWG), alongside numerous state and local partners, submit comments. Rooted in the lived experiences of survivors of domestic violence, dating violence, elder abuse, and other forms of coercive control, these comments address the pervasive issue of economic abuse, particularly coerced debt, and its devastating impact on marginalized communities. Coerced debt, defined as non-consensual credit-related transactions, traps victims in cycles of financial hardship and jeopardizes their physical safety. This response, informed by a nationwide survey of direct service providers, highlights the systemic barriers faced by victims attempting to utilize existing FCRA protections and proposes crucial regulatory changes to ensure that coerced debt is treated as a form of identity theft, thus providing survivors with a path to economic and physical security.
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