Saturday, May 27, 2006

Submit Your Complaints to the FTC Online

Federal Trade Commission Title: Advance Notice of Proposed RulemakingSubject Category: Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting

16 CFR Parts 660 and 661Published: March 22, 2006 View Notice (PDF) (Download Adobe Reader)Comments Due: Monday, May 22, 2006

How To Comment: The Commission in

vites interested parties to comment and submit information useful for developing guidelines and regulations required by Section 312 of the Fair and Accurate Credit Transactions Act. This is part of a joint rulemaking initiative where several agencies must:

establish guidelines for use by persons that furnish information to consumer reporting agencies regarding the accuracy and integrity of the furnished information and establish reasonable policies and procedures for implementing those guidelines.

Section 312 also requires the "Agencies" jointly to prescribe regulations that identify the circumstances under which a furnisher shall be required to reinvestigate a dispute concerning the accuracy of information contained in a consumer report based on a direct request of the consumer Privacy & Use The FTC Act and other laws the Commission administers permit the collection of public comments to consider and use in this proceeding as appropriate. All timely and responsive public comments, whether filed in paper or electronic form, will be considered by the Commission, and will be available to the public on the FTC Web site, to the extent practicable, at

Any information placed in the following fields on this form -- "Title," "First Name," "Last Name," "Organization Name,' "State," "Postal Code," "Country,' "Comments," and "Attachment" -- will be publicly available on the FTC Web site. Although filling out this comment form is voluntary, the fields marked with an asterisk are required in order for the FTC to fully consider a particular comment. As a matter of discretion, the FTC makes every effort to remove home contact information for individuals from the public comments it receives before placing those comments on the FTC Web site.

More information, including other routine uses permitted by the Privacy Act, may be found in the FTC’s privacy policy, at Accessibility If you are unable to access this form, click here for an alternate method of submitting a public comment.

Friday, May 05, 2006

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How to Comply with the Fair Credit Reporting Act Teleseminar series

How to Comply with the Fair Credit Reporting Act Teleseminar series

What: To supplement its online How to Comply with the FCRA subscription service (click here for more information), CDIA launched a series of distance learning opportunities to educate the industry on credit reporting issues.

Who: There are specific teleseminars are targeted at different groups that must comply with the FCRA:

• CDIA Members (Consumer Reporting Agencies); and• Non-Members of the CDIA (data furnishers, law professionals and more)

Where: Anywhere! You can participate in teleseminars from the comfort of your office, home or anywhere! These are distance-learning opportunities that save you travel costs and time. Materials are distributed to participants via CDIA's website or email prior to the call.
When: Teleseminars focusing on different issues will be offered throughout the year. Scroll down for a schedule of events. This schedule is updated throughout the year.

Please see the current schedule below for currently scheduled topics, dates and to download registration forms.

Upcoming Teleseminar Dates and topics:

Note: Subscribers to CDIA's How to Comply with the FCRA service receive discounts on this teleseminar series. Click here to subscribe or to learn more.

2006 CDIA How to Comply with the FCRA Teleseminars:
Click on each of the following teleseminar titles to learn more:

Legislation & State Law Updates: A CDIA Teleseminar Featuring CDIA Vice President and Counsel of State Government and Regulatory Affairs

New FTC Issued Consent Decree on Security Breach

New Identity Theft Red Flag Rule

Legislation & State Law Updates: A CDIA Teleseminar Featuring CDIA Vice President and Counsel of State Government and Regulatory Affairs.

Featured Speaker: Eric Ellman, Consumer Data Industry Association

• Thursday, May 4, 2006
2:00 p.m. - 3:00 p.m. Eastern

Program Highlights:
More than half of the states in the U.S. have FCRAs in effect. They not only differ from state to state but often raise compliance issues with the federal Fair Credit Reporting Act as well. Eric J. Ellman, Vice President and Counsel of State Government and Regulatory Affairs, will host a teleseminar on Thursday, April 20th & May 4th at 2:00 pm Eastern. Each teleseminar will survey state legislation in 2005 and highlight trends in new state laws that require legal and compliance attention for consumer reporting agencies, data furnishers, and data users. Included in this review will be legislation and laws that address security freezes, security breaches, the use of Social Security Numbers, and the use of credit header information.

Who Should Register: Companies who have to comply with FCRA current state laws across the United States

This call will be 60 minutes in duration and include a question and answer portion where participants can ask questions.

To register for this event, please click here.

“There was such a popular demand for this teleseminar that we are running it again on May 18th.”

FTC Issued Consent Decree on Security Breach(Speaker: Anne Fortney, Partner with the Hudson Cook, Moderator: CDIA President and CEO Stuart K. Pratt)

• Thursday, May 18, 2006
2:00 p.m. - 3:00 p.m. Eastern

CDIA has brought back by popular demand the teleseminar covering the FTC Consent Decree regarding ChoicePoint. On May 18th at 2:00 p.m., Anne Fortney, partner with The Hudson Cook law firm and former compliance official with FTC, will share her thoughts on the breach issue as it relates to the FTC actions earlier this year. Gain some insight on what this means for other companies that handle consumer information.

This event is open to both members of CDIA, as well as non-members (including data users, data furnishers and other that must comply with the FCRA).
To register for this event, please click here.

Identity Theft Red Flag Rule
Speaker: Amy Friend, Assistant Chief Counsel of the OCC, Moderator: CDIA President and CEO Stuart K. Pratt)

• Thursday, May 25, 2006
2:00 p.m. - 3:00 p.m. Eastern
Amy Friend, Assistant Chief Counsel of the OCC, will be available to discuss the Identity Theft Red Flag Rule at the CDIA teleseminar on May 25th at 2:00 p.m. The Rule, included in the 2003 FCRA FACTA amendments, is expected to be completed this month. You will hear not only a discussion of the just published Rule but also have your questions answered by the principal author of this Rule. You will be hearing more about this teleseminar in the coming weeks.

To register for this event, please click here.
How to Comply with the FCRA Subscription Information:
Non-Members should go to the CDIA E-Store at to subscribe to the How to Comply Service.

Members should logon to Members Only* at, select "Member E-Store" and then select "Online How to Comply with the FCRA," to purchase a subscription to How to Comply or sign up for a free 24-hour demo (redline not included in demo).

Please contact CDIAonline at with questions.
Can't participate in a Teleseminar?

Recordings are available for these events. CDIA offers Audio CDs on all its current and previous Teleseminars.

Again- Who and What is E-Oscar!

Consumer Data Industry Association (CDIA), in cooperation with Equifax, Experian, Innovis and TransUnion, is proud to announce the creation of a new state-of-the-art solution for processing ACDVs and AUDs. The new network, E-OSCAR, is the Online Solution for Complete and Accurate Reporting. E-OSCAR is a browser-based, Metro 2 compliant system that is secure, intelligent and intuitive.

E-OSCAR provides multiple benefits, as detailed below. We have enhanced our technology to be a web-based system. It was created with the awareness of the need for strong security around the sensitive data that will be sent through the network. We have provided a toll free industry Help Desk and, in addition, we have significant training resources available to you.

We know that as a leader in the credit industry who is concerned about the FCRA and data quality, you will want to be involved in the initial offering of E-OSCAR. Participation in the new network will provide key customers like you with any necessary personalized attention that you need during your transition. E-OSCAR is fully compliant with the new FCRA and so easy to use that you will want to become part of this new system!

Please begin the steps necessary to move from the current network onto the new one.
Alert your senior management to the upcoming changes. View the information links below to learn more about E-OSCAR. Make Use of the Implementation Checklist to plan your conversion.

What’s happening with E-OSCAR-webTM April 23, 2003

Valued Customer,

We are pleased to inform you that the E-OSCAR-web? Solution is complete and available for use. The Credit Community Network Service (CCNS) supported by Global eXchange Services (GXS, formerly GEIS) will no longer receive new ACDV transactions after May 15, 2003. You will be able to respond to these items until June 15, 2003.

In an effort to assist you with your transition and to ensure that your company is not adversely affected, the Consumer Data Industry Association (CDIA), Equifax, Experian, Innovis and TransUnion have prepared these instructions for you.

If you do not register with E-OSCAR and begin to use this solution to respond to disputes and/or submit automated Universal Data Forms, the National Consumer Reporting Agencies (NCRAs) will send your disputes via paper. In order to ensure that you do not receive paper disputes, you must follow the steps below and register with E-OSCAR

Register immediately at (If you have already registered, follow steps 3 and on).

We recommend that you print a copy of the registration you’ve completed, as well as, write down and keep in a safe place, the USER ID and password that you’ve created during the registration process.

Once you have received approval notice from one or more of the NCRAs, you should begin the on-line training. If you plan on having multiple users, now is the time to create a USER ID for each of those parties and be sure that all of the users have completed the on-line training prior to receiving ACDVs from the NCRAs.

During the next few weeks, we will begin the final phase of moving the transaction volume of customers from the GXS System to E-OSCAR. We would like to begin getting your AUDs as soon as your registration is approved. We will coordinate with you on transmitting your ACDVs, but we recommend beginning as soon as possible and no later than May 1.

During the registration approval process some of the NCRAs will provide you with a list of the reporting subscriber codes they show affiliated with your particular GXS mailbox. If a bureau does not, you may print off your existing Subscriber Code Table from your current GXS ACDV Software PC at your location. You will need to enter these codes into E-OSCAR after the NCRAs approve your registration. This will assist you in receiving all of your disputes via E-OSCAR without delay.

You must contact each of the NCRAs that you report to and coordinate a date that you would like to begin receiving your ACDVs. As soon as your subscriber codes are approved you may submit AUDs.

Submit the necessary request form to Global eXchange Services to cancel any active mailboxes. Please copy the NCRAs on your request (Addresses are listed at the bottom of this letter).
Respond to all ACDVs remaining in your GXS ACDV Mailbox.

Delete all subscriber codes associated with the mailbox using the GXS PC-based software; this will disable Mortgage Reporting Companies as well as NCRA Affiliates from utilizing the system thus allowing GEIS to effectively close the mailbox.

Call the E-OSCAR Help-Desk if you have any questions. 1-866-MY-OSCAR.

Contact Information: CCNS Administration Global eXchange Services, (GXS) 100 Edison Park Drive Gaithersburg, MD 20878 Help Desk (800) 892-1574 Fax- 301.340.4583

Equifax Credit Information Services Charles Saunders LaDeamya Mixon 1550 Peachtree St. Mail Drop 66N Atlanta, GA 30339 E-mail: Phone: 800-925-3329

Experian Patrick Sahf 701 Experian Parkway Allen, TX 75013. E-mail - Phone - 972-390-3610

TransUnion 2 Baldwin Place Crum Lynne, PA 19022 Fax - 610/546-4602 Tracy DeMarco Phone 610/546-4753 Email - Melissa Whayland Phone 610/546-4752 Email -

Innovis Data Solutions 950 Threadneedle, Suite 200 Houston, TX 77079-2900 Jose M Cruz Phone 281/504-2629 Email:

E-OSCAR Help Desk Phone 1-866-696-7227 (MY-OSCAR)

So the CRAs ARE E-Oscar. Interestingly, the Experian attorney Marc Carlson told me last week that I need to get info about reporting from E-Oscar. Nice try! I guess I’ll have to file another notice of deposition to get to an Experian person with a clue about E-Oscar. Experian has been extremely difficult and I need to file a motion to compel.

Experian ensures that people with 5+ year old charge-offs OFTEN have a credit score as if they had just defaulted in recent months. Their profits increase as the credit scores are lowered by their incorrect reporting. is where creditors log in. Submitting FACTUAL disputes sure doesn’t do the trick, so maybe that’s an alternative.

The PRIVATE domain registration:

Court Says Furnishers Face Reinvestigation Liability

The U.S. District Court for the Northern District of Illinois has ruled that consumers may sue those who furnish data to credit reporting agencies for failure to carry out their reinvestigation responsibilities under Section 623 of the FCRA. (Dornhecker v. Ameritech Corp., N.D. Ill., No. 00 C 26, 6/7/00). The judge ruled that while the FCRA does not specifically create such a liability, one could be implied from the way the law is written. The case involved telephone accounts that were fraudulently opened in some consumers names. When the subsequent debts were not paid, the phone company retained a collection firm to pursue the bad debts. The collector reported the adverse information to the credit reporting agencies and when the consumers found out about it they asked the credit reporting agencies for reinvestigation of the data as well as reported the fraud to the phone companies.

Two of the consumers sued the phone company, alleging it violated Section 623(b)(1) of the FCRA by failing to properly reinvestigate the disputed data. The phone company said it was only obligated to pursue a reinvestigation when contacted by the credit reporting agency. The consumers argued that furnishers duties under Section 623(b)(1) are indeed owed to consumers. They pointed out that Congress' exemption of furnishers from liability under subsection (a) implicitly made them liable under subsection (b). If Congress had meant to exempt furnishers from liability under subsection (b), it would have stated that fact as it did in subsection (a).

The court said it ruled as it did because it's apparent consumers are members of a class that the FCRA sought to protect and that legislative history shows an affirmative attempt by Congress to hold furnishers of information accountable if they continue to supply inaccurate data after they have been notified. It also backed its decision based on two cases that had been previously adjudicated.

The first involved a similar suit by a consumer over reinvestigation responsibilities under Section 623(b)(1). The court held that "there is no authority supporting the proposition that the FCRA does not create a private right of action". The court recognized that furnishers were exempt from civil liability from subsection (a), the FCRA did give consumers a cause of action against "persons" who are willful or negligent in complying with the Act.

The second citation concerned a case that set forth factors for determining if a private cause of action is implicit in a statute. Saying this case met all four factors, the court concluded that the consumers could file suit against furnishers of data for failing to comply with Section 623 (b)(1).

What is e-Oscar?

e-OSCAR is a web-based, Metro 2 compliant, automated system that enables Data Furnishers (DFs), and Credit Reporting Agencies (CRAs) to create and respond to consumer credit history disputes. CRAs include Equifax, Experian, Innovis and TransUnion, their affiliates or Independent Credit Bureaus and Mortgage Reporting Companies. e-OSCAR also provides for DFs to send "out-of-cycle" credit history updates to CRAs.

The system primarily supports Automated Credit Dispute Verification (ACDV) and Automated Universal Dataform (AUD) processing as well as a number of related processes that handle registration, subscriber code management and reporting.

ACDVs initiated by a CRA on behalf of a consumer are routed to the appropriate Data Furnisher based on the CRA and subscriber code affiliations indicated by the DF. The ACDV is returned to the initiating CRA with updated information (if any) relating to the consumer's credit history. If an account is modified or deleted, carbon copies are sent to each CRA with whom the DF has a reporting relationship.

AUDs are initiated by the DF to process out-of-cycle credit history updates. The system is used to create the AUD and route it to the appropriate CRA(s) based on subscriber codes specified by the DF in the AUD record. The e-OSCAR AUD process is intended to provide the CRA with a correction to a consumer's file that must be handled outside of the regular activity reporting cycle process. e-OSCAR may not be used to add or create a record on a consumer's file or as substitute for "in-cycle" reporting to the CRAs.

To see a demo of e-OSCAR-web, contact the Help Desk at 866-MY-OSCAR (866-696-7227) to obtain a temporary user id and password, then log into Call the e-OSCAR help desk at (866) MY OSCAR or (866) 696-7227.

Equifax Credit Information ServicesRichard Stinnett1550 Peachtree St.Mail Drop 66NAtlanta, GA 30339E-mail: Equifax.EOSCAR@equifax.comPhone: 678-795-7921 Effective Nov 15, 2005

Experiane-OSCAR Customer Support 701 Experian ParkwayAllen, TX 75013.E-mail: experian.e-oscar@experian.comPhone: 972-390-3610

TransUnionTransUnion e-OSCAR Customer Support LinePhone: 610-546-4762

Innovis Data SolutionsMichelle Junk1651 NW Professional PlazaColumbus, OH 43220Phone: 614-442-3710E-mail:

Thursday, May 04, 2006

The New Way Lenders Will Size You Up

Just when you finally had FICO figured out, you're getting a brand new score

By Amanda Gengler

April 18, 2006 11:03 PM EDT

(MONEY Magazine) – So the Fed raised rates another quarter point in March. Ho hum. The far bigger news that may affect your future borrowing rates: the unveiling of a new rating system that will compete with the widely used FICO credit score. Developed jointly by the three major credit bureaus, VantageScore should reduce discrepancies between your scores at the agencies, they contend. But it's also likely to lead to confusion, since VantageScore ratings will range from 501 to 990 (a 901-plus score is an A; 801 to 900, a B; down to 501 to 600, an F) vs. 300 to 850 for the FICO scale. For example, a 720 FICO score could land you a 9% rate on a credit card; with VantageScore, 720 might give you a 20% rate, says Curtis Arnold of For more info on the new system, go to

Tuesday, May 02, 2006

Fair Isaac Spotlights Latest Strategies and Innovations for Smarter Decisions at InterACT 06

CEO Grudnowski Delivers Insight into the Growing Impact and Applications of Enterprise Decision Management to Customers from 33 Countries

SAN FRANCISCO--(BUSINESS WIRE)--May 1, 2006--Fair Isaac Corporation (NYSE:FIC - News), the leading provider of solutions and technologies for Enterprise Decision Management (EDM), kicked off its 2006 North American InterACT customer conference today in San Francisco. In his opening address, CEO Tom Grudnowski discussed how Fair Isaac's ongoing pursuit of innovation is breaking new ground to help organizations transform and improve the way they make their most critical decisions.

InterACT, the world's leading business forum on business analytics, emerging decision management technologies and their applications, is being held this week in San Francisco, where Bill Fair and Earl Isaac started the company in 1956. Registered attendance of nearly 700 for the company's 50th anniversary conference is the highest in several years, demonstrating the growth in demand for EDM strategies and solutions.

Grudnowski told InterACT delegates that they are among the leading practitioners of EDM, which combines the analytic solutions and decision automation software organizations need to make their decisions more precise, more consistent and more agile, at every customer interaction or decision point. He also recognized clients' central role over the past 50 years in turning the company's solutions for risk management, fraud control, account management, business rules management and more into industry standards.

"We are very fortunate to have clients who understand and value what this company was born to do -- help organizations solve their most complex business problems by consistently making the right decisions at the right time," said Grudnowski. "We've been perfecting the science of EDM in our R&D labs, and working with you to perfect it in the form of thousands of successful deployments around the world. Bill Fair once said, 'We sell a radically different way of making decisions that flies in the face of tradition.' That was true in 1956, and it's still true today."
EDM Innovations in InterACT Spotlight

Key decision management innovations being showcased at InterACT 06 include:
Advances in the battle against fraud, including Fair Isaac's architecture for Enterprise Fraud Management, its vision of a fraud clearinghouse and its research into click fraud.
Fair Isaac's development of its ScoreNet® network, the first "Decision Services Provider" network. This growing network gives businesses access to hosted versions of Fair Isaac solutions, as well as more than 2,000 service providers and 70 third-party databases.
The latest release of Blaze Advisor(TM) business rules management system, the only such system powered by the Rete III algorithm. With Rete III, Blaze Advisor can run complex business rulesets up to 100 times faster than other rules engines.

The next phase in the company's EDM architecture for financial services, which will give banks a common platform for their decision management across the customer lifecycle, and connectivity between point solutions for different decision areas.

A new approach to customer-centricity called "CustomerHD," which uses leading-edge analytics to give marketers a high-definition view of customers and potential customers.
New insights into customer credit issues, including consumer sensitivity to debt load, U.S. and global regulatory issues in financial services, and the implications of HELOCs and debt consolidation for card issuers.

Today's general session also featured a keynote presentation by Jeffrey Sampler, a Fellow of Strategy and Technology at Oxford University and leading authority on how to manage information as a strategic resource for growth and innovation. Sampler provided perspectives on how to lead creatively, how to create business assets where none exist, and the power of the strategic vortex model -- building strategies one on top of the other.

About InterACT
InterACT brings together senior executives, business managers and analysts from the world's leading companies in financial services, insurance, retail, telecommunications, healthcare and the public sector. Fair Isaac began staging customer conferences in 1976 to provide the most-up-to-date insight and information on analyzing data for business decisions.
Over the next three days, InterACT participants can choose from more than 70 sessions, including case studies, research results, industry panels and strategy discussions on new EDM technologies and applications. Discussion groups and other conference events provide attendees with opportunities to connect with industry peers and Fair Isaac experts, and the InterACT Product Expo reveals Fair Isaac's latest analytic and decision management innovations.

About Fair Isaac

Fair Isaac (NYSE:FIC - News) makes decisions smarter. The company's solutions and technologies for Enterprise Decision Management give businesses the power to automate more processes, and apply more intelligence to every customer interaction. Through increasing the precision, consistency and agility of their decisions, Fair Isaac clients worldwide increase sales, build customer value, cut fraud losses, manage credit risk, reduce operational costs, meet changing compliance demands and enter new markets more profitably. Founded in 1956, Fair Isaac powers hundreds of billions of decisions per year in financial services, insurance, telecommunications, retail, consumer branded goods, healthcare and the public sector. Fair Isaac also helps millions of individuals manage their credit health through the website. Visit Fair Isaac online at

Statements Regarding Forward-Looking Information

Except for historical information contained herein, the statements contained in this press release that relate to Fair Isaac are forward-looking statements within the meaning of the "safe harbor" provisions of the Private Securities Litigation Reform Act of 1995. These forward-looking statements are subject to risks and uncertainties that may cause actual results to differ materially, including risks described from time to time in Fair Isaac's SEC reports, including its Annual Report on Form 10-K for the year ended September 30, 2005, and its quarterly report on Form 10-Q for the period ended December 31, 2005. Forward-looking statements should be considered with caution. If any of these risks or uncertainties materializes or any of these assumptions proves incorrect, Fair Isaac's results could differ materially from Fair Isaac's expectations in these statements. Fair Isaac disclaims any intent or obligation to update these forward-looking statements.

Fair Isaac, ScoreNet and Blaze Advisor are trademarks or registered trademarks of Fair Isaac Corporation, in the United States and/or in other countries. Other product and company names herein may be the trademarks of their respective owners.
Contact:Fair Isaac Corporation
Brian Kane, 612-758-5232
Source: Fair Isaac Corporation