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Financial Privacy

WPF urges the Federal Reserve Board of Governors to ensure quality assurance and control mechanisms for biometric authentication in debit card payment systems 

In comments filed with the Federal Reserve Board of Governors, WPF supported proposed language for Comment 235.7 (A)-1, Scope of Restriction , with the understanding that more needs to be done to determine and set quality assurance measures for debit card payment system authentication methods in general, and for biometric ...

Some Online Loan Applications Endanger Consumers

Have you ever filled out an application online for a “loan matching service”? If so, you have to hope that you didn’t fill out an application on one of the websites operated by a company called Blue Global. They ran websites like autoloansusa.com, loanmarketplace.com, moneytoday.com, 247loan.com, 100dayloans.com, and others. Court documents released this week by the US Federal Trade Commission reveal that after the company collected consumers' financial information, it sold most of that information to non-lenders, including SSNs, bank account numbers, and ...

Consumer Tips: World Privacy Forum's Top Ten Opt Outs

Many people have told us that they think opting out is confusing. We agree. Opting out can range from the not-too-difficult (the FTC’s Do Not Call list is a fairly simple opt out) to the challenging (the National Advertising Initiative opt out can be tricky). Our hope is that this list will clarify which opt out does what, and how to go about opting out.

Collections Scoring, Privacy, and Consumer Impacts

This coming Thursday, Pam Dixon will be presenting new research on collections scoring, privacy, and impacts on low and middle income consumers. The Dixon/Gellman report, The Scoring of America , sparked a national conversation about analytics and fairness in the realm of consumer scores. This talk focuses on one particular ...

Financial Privacy | Public Comments: WPF urges caution in creating new unique mortgage identifier number

WPF submits comments to CFPB about the Universal Mortgage Identifier number and Home Mortgage Disclosure Act The World Privacy Forum has recommended privacy controls for a proposed Universal Home Mortgage Identifier number, along with other privacy protections to the Consumer Financial Protection Bureau in public comments on the Home Mortgage ...

Public Comments: WPF files comments urging the SEC to protect asset-level data privacy of consumers

The World Privacy Forum submitted comments to the Securities and Exchange Commission today requesting that the SEC do more to protect the privacy of consumers' asset information. Asset information -- the financial information attached to mortgages, car loans, and other consumer borrowing activities-- is very attractive to the consumer data industry. We would be happier with the current SEC proposal if it were practical to keep all sensitive asset-level data under the direct control of the Commission or, perhaps, the Consumer Finance Protection Bureau. Direct involvement by a federal agency, while no guarantee of a better outcome for data subjects, would provide better and clearer accountability for maintenance of the data as well as the possibility of meaningful enforcement.

Letter to FTC re: Equifax sales of consumer info to predatory lenders

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.

Public Comments: January 2012 - Regarding Disclosure of Certain Credit Card Complaint Data

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.

Top Ten Opt Out list updated

Opt-out and how-to -- The popular WPF Top Ten Opt Out List has been newly updated. We have added a new section to our list with step by step details on how to opt out of RapLeaf. We encourage consumers to view any of their profiles that exist at RapLeaf and to opt out of RapLeaf permanently. We have also updated the phone numbers and other information on the rest of our opt out list. To see more, visit our Opt Out List.

Public Comments: August 2010 - WPF files comments on deeply flawed SEC plan

The World Privacy Forum filed comments today criticizing the SEC proposed regulations that would release an unprecedented amount of financial details about individual borrowers through the EDGAR database. The WPF was joined by other privacy, consumer, and human rights organizations in its comments, which focused on the privacy issues with the proposed regulations. Pam Dixon, executive director of the WPF, stated in the comments that the SEC's new regulations would "Place on the public record and online the largest amount of personal financial information about borrowers ever disclosed, including information never before made public." The comments also note that the SEC's plan greatly increases the risk of identity theft for individual borrowers whose information will be released publicly.

WPF files comments on deeply flawed SEC plan

Financial privacy and SEC -- The World Privacy Forum filed comments today criticizing the SEC proposed regulations that would release an unprecedented amount of financial details about individual borrowers through the EDGAR database. The WPF was joined by other privacy, consumer, and human rights organizations in its comments, which focused on the privacy issues with the proposed regulations. Pam Dixon, executive director of the WPF, stated in the comments that the SEC's new regulations would "Place on the public record and online the largest amount of personal financial information about borrowers ever disclosed, including information never before made public." The comments also note that the SEC's plan greatly increases the risk of identity theft for individual borrowers whose information will be released publicly.

WPF Resource Page: State Security Freeze Laws and General Information

A credit freeze (sometimes called a security freeze) lets you stop the disclosure of your credit report by a credit bureau. Currently, the three credit bureaus are allowing all consumers nationwide to set a security freeze for a fee. Some states have specific security freeze laws; a list of states with security freeze laws may be found below. However, even if you live in a state without a security freeze law, you can still set a security freeze.

WPF asks Treasury to get consumers' consent before checking their credit reports

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.

Public Comments: August 2009 - WPF asks Treasury to get consumers' consent before checking their credit reports

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.

OECD reaffirms its support for the 1980 OECD principles on privacy, or "Fair Information Practices"

OECD | Fair Information Practices -- At a key meeting of the OECD on the future of the Internet economy, the OECD Secretary General Angel Gurria reaffirmed support of the 1980 OECD Privacy Principles. Also, Secretary General Angel Gurria expressed support for formalizing the participation of civil society in OECD going forward and for paying more attention to information security and identity theft problems. Secretary General Gurria noted that "A more decentralised, networked approach to policy formulation for the Internet Economy that includes the active participation of stakeholders needs to be the norm." Many parts of the recent OECD meeting may be viewed online.

World Privacy Forum, NCLC, and Consumer's Union file extensive comments regarding accuracy of credit reports

Financial privacy / credit reports -- The NCLC, Consumer's Union, and the World Privacy Forum filed extensive joint comments today regarding the proposed rulemaking, Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies under Section 312 of the Fair and Accurate Credit Transactions Act. The results of the proposed rulemaking will have a significant impact on how the accuracy of credit reports is defined for consumers, and will have a substantive influence over how consumers may handle credit report disputes directly with those who furnish information for the reports.

Opportunity for public comment on the accuracy of credit reports

Financial privacy | credit reports -- Consumers and organizations have an opportunity to submit public comments about the accuracy and integrity of credit reports. Until February 11, the Federal Reserve Board, the Federal Trade Commission and other banking agencies will be accepting comments on their draft rulemaking regarding how creditors and other furnishers provide information to consumer reporting agencies, and which types of direct disputes they must handle. This proposed rulemaking is a key one; it defines what accuracy and integrity of information provided to consumer reporting agencies means, how disputes may be handled directly with the furnishers, and which types of direct disputes furnishers may ignore. The NCLC, Consumer's Union, and the World Privacy Forum have written a sample letter that may be downloaded and used or modified for the comments. To file your letter, submit your comments to the Board of Governors of the Federal Reserve System by mailing the comments to regs.comments@federalreserve.gov with the subject line "Docket No. R–1300."

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