In 2012, the US Federal Trade Commission brought a remarkable case against Equifax for selling consumer financial information — which included credit scores and late mortgage payment information– to companies offering services to consumers in financial distress. The World Privacy Forum commented to the FTC on this case, which was important for a number of reasons.
The World Privacy Forum appreciates the opportunity to submit comments to the Consumer Financial Protection Bureau’s (CFPB) proposed policy statement about the CFPB’s proactive disclosure of credit card complaint data. The proposed statement appeared in the Federal Register on December 8, 2011 at 76 Federal Register 76628, http://www.gpo.gov/fdsys/pkg/FR- 2011-12-08/pdf/2011-31153.pdf and at https://www.federalregister.gov/articles/2011/12/08/2011-31153/disclosure-of-certain-credit- card-complaint-data.
Financial privacy – Privacy Act — The World Privacy Forum filed comments today urging the U.S. Treasury Department to obtain consumers’ consent before checking their credit reports. Consumers who participate in the government’s Home Affordable Modification Program (HAMP) — an Obama administration program created to help consumers renegotiate their mortgages so they can keep their homes — must allow the Federal Government to check their credit reports without first obtaining consent. This procedure sets a negative precedent, and is at odds with consumer expectations of privacy. The Treasury gave itself this power in an obscure set of “Routine Uses” in a Privacy Act notice published along with the proposed system of records for the program. The World Privacy Forum has objected to this, and has filed detailed comments with the Treasury about the lack of consumer consent. The public comment period on this program is open until September 4, 2009.
The World Privacy Forum filed comments today urging the U.S. Treasury Department to obtain consumers’ consent before checking their credit reports. Consumers who participate in the government’s Home Affordable Modification Program (HAMP) — an Obama administration program created to help consumers renegotiate their mortgages so they can keep their homes — must allow the Federal Government to check their credit reports without first obtaining consent. This procedure sets a negative precedent, and is at odds with consumer expectations of privacy. The Treasury gave itself this power in an obscure set of “Routine Uses” in a Privacy Act notice published along with the proposed system of records for the program. The World Privacy Forum has objected to this, and has filed detailed comments with the Treasury about the lack of consumer consent. The public comment period on this program is open until September 4, 2009.
Financial privacy — U.S. consumers have the right to order one free credit report per year from each of the three national credit bureaus. The World Privacy Forum’s landing page about federally-mandated free Annual Credit Reports and the consumer tips for ordering a free annual credit report have been fully updated.