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PostPosted: Tue Dec 19, 2006 11:28 pm 
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Posts: 1687
Comment Number: 514719-00017
Received: 3/12/2005 8:42:24 PM
Organization: ECO
Commenter: Thad Fendley
State: AL
Agency: Federal Trade Commission
Rule: Notice of Proposed Study on the Effects of Credit Scores and Credit-based Insurance Scores on the Availability and Affordability of Financial Products
Docket ID: 3084-AA94
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Comments:

Credit scores are a valuable at determining risk, but should be weighed less than they currently are. CRAs have found ways to minipulate scores through backdoor reaging and hinge on the part in the FCRA that keeps the scoring models under lock and key. Even the craftiest of financiers cant predict the score change in relations to a credit report tradeline change, and the score should be a number that dictates the credit report as is, not as result of a consumer initiated investigation. There is great disparitiy in the system of scoring, but the intention is being served by few. I'll give you the biggest disparity as an example. Experian currently reports a "status date" if a field, that by their definition is the date the furnisher supplied the information. Fair Isaac reads this field as a "date of last activity" in its scoring model. So, if a consumer intiates an investigation the "status date" is advanced to reflect a response from the furnisher. If this tradeline was a negative tradeline the consumer can expect to see a 20 to 35 point decrease in score. This consumer may have not missed a payment in over 2 years, but fell victim of backdoor reaging for exercises his/her rights as a consumer by requesting an investigation, becauses Fair Isaac reads this date as recent account activity. Until problems like this are fixed, it will never be %100 accurate. I'm waiting for the first Congressman with an innacurate credit report to realize this and do something. Personally, If you recieved a large score decrease apon disputing, would you do it again?

http://www.ftc.gov/os/comments/FACTA-im ... -00017.htm

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David Szwak
Chairman, Consumer Protection Section, Louisiana State Bar Association
Bodenheimer, Jones & Szwak
509 Market Street, 7th Floor
Mid South Tower
Shreveport, Louisiana 71101
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