This NCLC comment expresses strong opposition to changes proposed by the Consumer Data Industry Association (CDIA) that would throttle the number of complaints filed with the CFPB against the three Big Three credit bureaus (Experian, Equifax and TransUnion).
The comments object to the CFPB’s action in already adopting one of the changes demanded by CDIA, i.e., the addition of several pages of intimidating warning notices that instruct consumers they must first submit a dispute with the credit bureaus and wait 45 days before they can file a complaint with the CFPB. NCLC urges the CFPB to remove these warning notices because they will deter consumers from filing complaints, cause unjustified time burdens, and mis-state the law.
Other changes proposed by CDIA include
- restricting the submission of multiple complaints from one IP address, which would prevent consumers from using locations to file complaints such as libraries, schools, social services providers, legal services offices, and domestic violence shelters.
- implementing two factor authentication using a phone number, and restricting the number of complaints from a phone number, which would harm consumers who need to file multiple complaints because of identity theft or mixed credit files involving dozens of accounts.
- allowing credit bureaus to remove a complaint from the complaint totals if they think the consumer did not contact them first.
- requiring more identification from consumers, which credit bureaus have a history of demanding excessive amounts of and also presents data security risks.
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