Public Comment ANPR FACTA Evan Hendricks

Office of Evan HendricksIn Re: OCC and Docket Number 06–04 RIN 1557–AC89 12 CFR Part 41 ‘‘Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies’’ The following comments are submitted on behalf of: Sherwin Siy Ken McEldowney, Executive Director Staff Counsel CONSUMER ACTION Electronic Privacy Information Center 221 Main Street, Suite 480 1718 Connecticut Ave. NW, Suite 200 San Francisco, CA 94105 Washington, DC 20009 www.consumer-action.org www.epic.org Linda Ackerman, Staff Counsel Robert Ellis Smith Privacy Activism Publisher www.privacyactivism.org Privacy Journal P.O. Box 28577 Providence, RI 02908 Evan Hendricks, Editor/Publisher www.privacyjournal.net Privacy Times P.O. Box 302 Beth Givens, Director Cabin John, MD 20818 Privacy Rights Clearinghouse www.PrivacyTimes.com San Diego, CA 92103 CreditScoresandCreditReports.com www.PrivacyRights.org Most of the information in these comments is documented in Evan Hendricks’ book, “Credit Scores and Credit Reports: How The System Really Works, What You Can ndDo.” (2 Edition, Privacy Times, 2005). Routine practices of furnishers regularly contribute to credit report inaccuracy, and need to be changed systematically across industry. The inter-agency guidance should expedite such change by specifying the shortcomings in the current system. The ‘CDV Exchange’ Often Does Not Constitute An Investigation When a consumers disputes ...