# Under Section 319 of the

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URL: https://www.frixlaw.com/law-library/documents/agency%3Aftc%3A553b20a47cfa8a9b

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

Report to Congress
Under Section 319 of the
Fair and Accurate Credit
Transactions Act of 2003

January 2015

Federal Trade Commission
Edith Ramirez

Chairwoman

Julie Brill

Commissioner

Maureen K. Ohlhausen

Commissioner

Joshua D. Wright

Commissioner

Terrell McSweeny

Commissioner

Report Contributors
Beth A. Freeborn, Economist, Bureau of Economics, Division of Consumer Protection
Julie Miller, Research Analyst, Bureau of Economics, Division of Consumer Protection

Contents
Executive Summary .................................................................................................................... i
1

Introduction .........................................................................................................................1
1.1

Overview of the Credit Reporting Industry....................................................................1

1.2

Previous Reports to Congress: 2004, 2006, 2008, and 2010...........................................3

1.3

2012 FTC Credit Report Accuracy Study ......................................................................3

1.3.1

Methodology..........................................................................................................4

1.3.2

Results of 2012 FTC 319 Accuracy Study ..............................................................6

2

Changes within the Credit Reporting Industry Following the 2012 FTC 319 Study..............7

3

Follow-Up Study .................................................................................................................9
3.1

Reinsertion of Negative Information ...........................................................................10

3.2

Follow-Up Interview Sample ......................................................................................13

3.3

Unresolved Disputes ...................................................................................................14

3.3.1

Unresolved Items: Notification by the CRA .........................................................16

3.3.2

Unresolved Items: Communication of Reasoning .................................................16

3.3.3 Unresolved Items: Acceptance and Continued Disagreement over Original
Information .......................................................................................................................17
3.3.4
3.4
4

Unresolved Items: Continue to Dispute ................................................................18

Items Alleged as “Not Mine” ......................................................................................20

Conclusion ........................................................................................................................21

Appendix A: Confidence Intervals ........................................................................................... A1

Executive Summary
Pursuant to Section 319 of the Fair and Accurate Credit Transactions Act (“FACT Act”), the
Federal Trade Commission (“FTC”) submits its sixth interim and final report on a national study
of credit report accuracy.
Section 319 of the FACT Act requires the FTC to conduct a national study of the accuracy and
completeness of consumer credit reports. The results of the national accuracy study are described
in detail in the Report to Congress under Section 319 of the Fair and Accurate Credit
Transactions Act of 2003 (December 2012) (“2012 FTC 319 Study”). This report (“Follow-Up
Study”) is an extension of the main study fully described in the 2012 FTC 319 Study.
The FTC contracted a research team to collect data for this national study of credit report
accuracy and contracted the same research team to conduct a Follow-Up Study in the year
following the collection of the data for the main study. The research team included members
from the University of Missouri, St. Louis (UMSL), the University of Arizona, and the Fair Isaac
Corporation. At the conclusion of the study, the contractor provided data in a de-identified
format as well as a report summarizing the findings; the contractor’s report is included as
Appendix B. Economists in the Bureau of Economics at the FTC independently analyzed the
data and drafted this report.
2012 FTC 319 Study
The 2012 FTC 319 Study was the first national study designed to engage all the primary groups
that participate in the credit reporting and scoring process: consumers, lenders/data furnishers,
the Fair Isaac Corporation (“FICO”), and the national credit reporting agencies (“CRAs”). In
brief, the 2012 study design called for 1,001 randomly selected consumers to review their three
national credit reports with a study associate who helped them identify potential errors. Study
participants were encouraged to use the Fair Credit Reporting Act (“FCRA”) dispute process to
challenge potential errors that might have a material effect on the participant’s credit standing
(i.e., potentially change the credit score associated with that credit report). After the completion
of the FCRA dispute process, study participants were provided with new credit reports and credit
scores. The new credit reports were compared with the old reports to assess whether
modifications were made by the CRAs in response to the consumer disputes.
Findings from the 2012 FTC 319 Study
The 2012 FTC 319 Study is described in more detail herein, along with a brief discussion of
changes made within the credit reporting industry following the release of the study. Here we
summarize the main findings from the 2012 study.
• Of the 1001 participants, 262 consumers (26%) identified at least one potentially material
error on at least one of their three credit reports.
• When the redrawn credit reports were reviewed, we found that 206 consumers (21% of
the total participants) had a modification to at least one of their credit reports after the
dispute process.
• There were 129 consumers (representing 13% of total participants) who experienced a
change in their credit score as a result of these modifications.
i

•

•

Of the 129 consumers with any score change, more than half experienced a maximum
change in score of fewer than 20 points. (Each affected participant may have as many as
three score changes and so we focused on the largest score change the consumer
experienced after receiving a modification.)
Lastly, the 2012 FTC 319 Study examined score changes that resulted in the consumer
moving from one credit risk tier to another. Out of the entire population of participants,
we found that 52 consumers (5% of the total participants) experienced an increase in
score such that their credit risk tier decreased and the consumer may have been more
likely to be offered a lower auto loan interest rate. Conditional on identifying and
alleging an error, 20% (52 out of 262 consumers with disputes) experience this
meaningful credit score increase.

Although the 2012 FTC 319 Study contains the main assessment of credit reporting accuracy at
the time, the main study revealed a number of issues of interest to policymakers, thus leading to
additional data collection for this Follow-Up Study. First, this Follow-Up Study quantifies the
frequency of reinsertion, or the reappearance of previously removed negative information. Next,
the Follow-Up Study investigates several questions relating to the consumers who disputed items
that were not modified in the original dispute process. Specifically, we assess whether consumers
continue to allege inaccuracies after the CRA has verified the disputed information as accurate,
whether consumers recall receiving notifications and explanations from the CRA when
information was not modified, and whether consumers plan to continue their disputes.
Unresolved Disputes
In the 2012 FTC 319 Study, a consumer is classified as having a confirmed material error if the
consumer experienced a modification in response to the dispute. However, many consumers did
not receive any modifications, and a substantial number experienced modifications but also had
some disputed items remain unchanged on their credit reports. At the conclusion of the 2012
FTC 319 Study, an unchanged item may be considered unresolved, since the consumer initially
stated the item was an error and the CRA disagreed. These unresolved items could potentially
continue to be disputed if the consumer continues to allege the items are inaccurate. Throughout
the report, we will refer to these types of disputes as “unresolved,” although we recognize these
disputes are only potentially unresolved from the consumer perspective. From the CRA
perspective, the items were investigated and verified as accurate. This Follow-Up Study explores
the discrepancy at the end of the initial dispute process with respect to unresolved items by
conducting a follow-up interview with consumers who have disputed items unchanged on their
credit reports.
All information on unresolved disputes provided in this Follow-Up Study is self-reported by the
consumer. Following the 2012 FTC 319 Study, a large number of consumers had unresolved
items on their credit reports. The contractor was able to contact 68% of 179 participants who
were eligible for the follow-up interview due to an unresolved dispute, resulting in 121 follow-up
interview participants. Because some eligible consumers were not able to be contacted and did
not participate in the Follow-Up Study, the follow-up participants represent a sample of the
eligible participants. We performed some basic statistical analyses to show that the follow-up
interview sample of consumers is generally representative of the type of disputes filed by the
population of participants in the main study.
ii

Although the follow-up interview was conducted a year after the initial contact with consumers
and represents a sample of the eligible participants, the consumer responses to the interview
questions revealed several noteworthy features regarding the unresolved items.
Summary of Follow-Up Study Findings
• Acceptance of CRA Decision: Of the 121 consumers who had at least one unresolved
dispute and participated in the follow-up interview, 37 consumers (31%) stated that they
now accepted the original information as correct, thus accepting the decision of the CRA.
• Continuation of Dispute: The majority of follow-up interview participants (almost 70%)
still believe that at least one piece of previously disputed information is inaccurate. Of
these 84 consumers who continue to believe the disputed information is inaccurate, 38
consumers (45%) plan to continue their dispute(s), 42 consumers (50%) plan to abandon
their dispute(s), and 4 consumers (5%) are undecided.
• Reasoning for Abandoning Disputes: As noted above, half of the consumers who
believe their disputes are still valid and that they still have inaccurate information on their
credit reports choose not to continue their disputes. Because consumers may have
disputes at multiple CRAs, this results in 42 consumers abandoning 93 potential disputes.
The most common reason given for abandoning the dispute process is that consumers feel
that the inaccurate information is not important or the consumer is not interested in
pursuing the matter (40%). For another 23% of the unresolved and abandoned disputes,
the consumers indicated that they do not have enough time to continue the dispute.
• Notification and Explanation: Of the 121 consumers who had at least one unresolved
dispute and participated in the follow-up interview, 49 consumers (40%) stated that they
did not receive a notification from the CRA that the item was not changed. Of the 56
consumers who stated they received a notification, over half (29 consumers) stated that
no explanation was provided by the CRA for the lack of modification.

Reinsertion
A great deal of law enforcement and policy work in the mid-1990’s addressed the issue of
reinsertion on credit reports of previously deleted information, culminating in the 1996
Amendments to the FCRA. One aspect of the 1996 Amendments required data furnishers (who
provide information to CRAs) to delete, modify, or permanently block the reporting of disputed
information that was found to be inaccurate, thus reducing the likelihood of negative information
being reinserted. As a result of this regulatory requirement, we would expect reinsertion to be
relatively infrequent. The credit report “reinsertion” rate, however, has been essentially
impossible to objectively ascertain because it requires analysis of credit reports that have been
modified in response to a consumer dispute. Given the large sample of consumers in the main
study who experienced modifications in response to disputes (206 consumers), the study
associates were able to redraw the modified credit reports a year after the modifications appeared
for 202 of those consumers and assess the rate of reinsertion.
•

Of the 202 consumers who received modifications during the original dispute process in
the 2012 FTC 319 Study and whose reports were redrawn a year later, 2 consumers (1%)
each had one previously removed negative information item reappear on their credit
iii

report. The two consumers who experienced reinsertion had disputed different types of
information at different CRAs, so reinsertion does not appear to be systematic at a
particular CRA. While it is reassuring to find that reinsertion is relatively rare, the
continued presence of the reinsertion issue suggests that consumers, the CRAs, and
policymakers must remain vigilant regarding the reappearance of negative information.

Recommendations
Although the findings from the Follow-Up Study are interesting, due to the relatively small
number of consumers who participated in the follow-up interview, the Commission has
determined not to recommend any specific legislative action regarding credit reporting accuracy
at this time.
However, given the findings of the Follow-Up Study, we recommend that
• The CRAs review and improve the dispute results notification process to ensure the
notices and explanation of investigation results are provided to consumers.
• The CRAs continue to explore efforts to educate consumers regarding their rights to
review their credit reports and dispute inaccurate information.
• Consumers continue to examine their credit reports annually by using
https://www.annualcreditreport.com and follow the FCRA dispute process when
inaccuracies are identified. Following the resolution of a dispute, consumers should
continue to check their credit reports for potential rare instances of reinsertion.

iv

1

Introduction

The Federal Trade Commission (“FTC” or “the Commission”) submits this report pursuant to
Section 319 of the Fair and Accurate Credit Transactions Act of 2003 (“the FACT Act”). The
FACT Act amends the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (“FCRA”) and
contains a number of provisions designed to enhance the accuracy and completeness of credit
reports. Section 319 of the FACT Act requires the Commission to conduct:
an ongoing study of the accuracy and completeness of information contained in consumer
reports prepared or maintained by consumer reporting agencies and methods for
improving the accuracy and completeness of such information. 1
Congress instructed the FTC to complete this study by December 2014. Further, starting with the
interim 2004 report, a total of five interim reports were required over respective two-year
intervals. The results of the national accuracy study are described in detail in the Report to
Congress under Section 319 of the Fair and Accurate Credit Transactions Act of 2003
(December 2012) (“2012 FTC 319 Study”). This report is the sixth and final report and
represents an extension of the 2012 FTC 319 Study.

1.1 Overview of the Credit Reporting Industry2
The U.S. credit reporting industry consists primarily of three national CRAs that maintain a wide
range of information on approximately 200 million consumers. 3 Roughly 30,000 data furnishers,
including creditors, collections agencies, public offices, and others voluntarily submit
information to these centralized, nationwide repositories of information. The submitted
information is attached to identifying information such as name, Social Security number

1

“Completeness” as used in Section 319 of the FACT Act refers to the quantity of
information in a consumer’s file that would be increased by the addition of more transactions,
such as those referred to in FACT Act Section 318(a)(2)(D) and (E) to the consumer reporting
system. For example, a file would be more “complete” if it included information about the
consumer’s rental payments.
2
For a more complete discussion of the Fair Credit Reporting Act of 1970 (FCRA) and the
relevant amendments of 1996 and the 2003 FACT Act, please see the 2004 FTC 319 Report or
40 Years of Experience with the Fair Credit Reporting Act: An FTC Staff Report with Summary
of Interpretations (July 2011) (hereinafter “2011 FTC FCRA Report”) available at
http://www.ftc.gov/os/2011/07/110720fcrareport.pdf.
3
See Robert B. Avery, Paul S. Calem, Glenn B. Canner & Raphael W. Bostic, An Overview
of Consumer Data and Credit Reporting, Federal Reserve Bulletin (Feb. 2003), (hereinafter
“2003 FRB Study”); and also The Accuracy of Credit Report Information and the Fair Credit
Reporting Act: Hearing Before the Senate Committee on Banking, Housing, and Urban Affairs,
108th Cong. (July 10, 2003) (statement of Stuart K. Pratt, Consumer Data Industry Association
(“CDIA”)) (hereinafter “Statement of Stuart K. Pratt”).
1

(“SSN”), address, or birth date. 4 The CRAs organize these records into “files,” which refer to all
data that the CRA believes belong to the same person. Users of credit reports analyze the data
and other information to assess the risk posed by credit applicants, often using sophisticated
predictive models called credit scores. 5 This flow of information enables credit grantors and
others to make fast and generally reliable decisions about a consumer’s eligibility for various
products and services, allowing consumers to obtain credit within minutes of applying.
Since 1996, the FCRA has also imposed certain accuracy and reinvestigation duties on both the
furnishers of information to CRAs and the users of reports. For example, users of consumer
reports (i.e., creditors who use report information provided by CRAs) are required to send notice
to consumers if the consumer’s credit report was used to deny credit (known as an “adverse
action notice”). The 2003 FACT Act imposed additional reinvestigation duties on furnishers.
These amendments also recognize that furnishers – the original source of the information – have
a critical role to play in the overall accuracy of consumer report information. Thus, Section 623
of the FCRA requires furnishers to investigate disputes received from CRAs and to correct and
update information provided to CRAs that they later learn is inaccurate. Furnishers are also
required to investigate and respond to disputes made directly to them by consumers regarding the
accuracy of their information.
For additional discussion of the importance of studying credit reporting accuracy and non-FTC
studies of accuracy, please see the 2012 FTC 319 Study.

4

Identifying information is used to link information provided by different furnishers and to
determine to which consumer file a subscriber’s inquiry pertains. Although the SSN is a unique
identifier, it is often missing from consumer credit information and errors in recording SSNs
occur. The CRAs do not require that subscribers submit a SSN as part of an inquiry and some
creditors do not require consumers to provide a SSN as part of a credit application. Errors in
SSNs may arise when a consumer does not know his or her number when filling out an
application, from illegible handwriting or faulty transcription, or from mistyping the number
when entering it into a database. Because of these problems, the CRAs do not rely exclusively on
SSNs in their matching procedures. Instead, the CRAs will rely on SSNs that do not match if the
match on other data elements is strong enough. (See 2004 FTC 319 Report).
5
Scoring products (including “risk scores” and “credit scores”) are predictive models based
on analyses of historical consumer credit history and performance data. When a consumer
applies for credit or insurance, the models use information in the consumer’s credit history to
predict the risk posed by that consumer. The risk is typically summarized in a numerical score.
There are many different types of credit scores in use today. Each of the national CRAs offers a
variety of scores, such as scores that measure general creditworthiness, scores that are specific to
certain types of credit such as auto loans or mortgages, and credit-based scores used to measure
risk for auto or homeowners insurance, default risk, or bankruptcy risk. Some of these scores are
developed by the CRAs themselves (e.g., VantageScore) and others are developed by third
parties (e.g., the Fair Isaac Corporation developed and produces the widely used “FICO” scores).
2

1.2

Previous Reports to Congress: 2004, 2006, 2008, and 2010

In 2004, the FTC delivered the first report to Congress in response to Sections 318 and 319; this
initial report was a thorough literature review and exploration of the potential accuracy issues in
credit reporting. 6 In reviewing the literature, it became clear there was no statistically reliable,
nationally representative study on consumer credit reporting accuracy. The initial 2004 FTC 319
Report laid the groundwork for the subsequent large-scale consumer study completed in 2012.
As part of the FTC 319 Accuracy Study, the Bureau of Economics conducted two pilot studies
described in the 2006 and 2008 reports to Congress. 7 These pilot studies helped to clarify certain
issues of studying accuracy, such as sample selection and what constitutes a meaningful error
(discussed in more detail below). The 2006 and 2008 FTC 319 Reports to Congress develop a
more complete methodology for assessing inaccuracies in credit reports; that is, the pilot studies
revealed the need for the involvement of the consumer, the data furnishers, the credit reporting
agencies (“CRAs”), and the use of the FCRA dispute process to identify confirmed errors. The
final methodology was put in place in late 2009; the 2010 FTC 319 Report described the full
methodology in detail and reported the status of the nationally representative study at that time. 8

1.3

2012 FTC Credit Report Accuracy Study

The 2012 FTC 319 Study described in the Report to Congress under Section 319 of the Fair and
Accurate Credit Transactions Act of 2003 (December 2012) presented the results of the
nationally representative study and was delivered to Congress in December 2012. 9 The overall
6

Report to Congress under Sections 318 and 319 of the Fair and Accurate Credit
Transactions Act of 2003, Federal Trade Commission, December 2004, at 22-31 (hereinafter
“2004 FTC 319 Report”), available at http://www.ftc.gov/reports/facta/041209factarpt.pdf.
7
Report to Congress under Section 319 of the Fair and Accurate Credit Transactions Act of
2003, Federal Trade Commission, December 2006 (hereinafter “2006 FTC 319 Report”),
available at http://ftc.gov/reports/FACTACT/FACT_Act_Report_2006.pdf and Report to
Congress under Section 319 of the Fair and Accurate Credit Transactions Act of 2003, Federal
Trade Commission, December 2008 (hereinafter “2008 FTC 319 Report”), available at
http://ftc.gov/os/2008/12/P044804factarptcongress.pdf.
8
Report to Congress under Section 319 of the Fair and Accurate Credit Transactions Act of
2003, Federal Trade Commission, December 2010 (hereinafter “2010 FTC 319 Report”),
available at http://www.ftc.gov/reports/section-319-fair-accurate-credit-transactions-act-2003fourth-interim-federal-trade.
9
We engaged the services of an academic contractor from University of Missouri, St. Louis
for data collection purposes. During January 2010, the FTC solicited competitive bids for
performing certain work for the 319 FACT Act Study. The Statement of Work is attached to the
2012 Report. The complete solicitation may be found on FedBizOps, FTC-10-Q-0007, January
22, 2010. The FTC’s full study contractor is a research team comprised of members from the
Center for Business and Industrial Studies at the University of Missouri-St. Louis (UMSL), the
Norton School of Family and Consumer Sciences at the University of Arizona (UA), and the Fair
Isaac Corporation (FICO) [hereafter the entire research team is referred to as “the contractor”].
3

objective of the 2012 FTC 319 Study was to assess the rate of errors in consumer credit reports.
Previous studies of credit report accuracy did not use nationally representative samples or did not
engage all the primary agents in the credit reporting and scoring process. 10 The 2012 FTC 319
Study was novel in its design, which included consumers, data furnishers, CRAs, and FICO.

1.3.1 Methodology
As noted above, the 2006 and 2008 pilot studies made clear the difficulties in generating a
nationally representative sample. Specifically, the pilot studies revealed that consumers with
lower scores were both less likely to participate in a voluntary study and more likely to have
material errors. Thus, the 2012 FTC 319 Study utilized a stratified sampling procedure. The three
national CRAs (Equifax, Experian, and TransUnion) voluntarily provided VantageScore credit
scores, zip code, gender and age for a large random sample of consumers. 11 This master list was
then adjusted so that the study participants from a given CRA were proportional to its database,
resulting in a total of 174,680 consumers in the sampling frame. 12
From this large sample of consumers, the FTC mailer contractor sent invitations to consumers
asking them to participate in the study to assess accuracy in credit reports. Due to variation in
response rates, proportionally more invitations were sent to individuals with below-average
credit scores to ensure that these consumers were adequately represented in the study. 13 As the
This same research team was employed for the two pilot studies and the Follow-Up Study
described below. The credentials of the research team are appended to the 2008 FTC 319 Report.
10
In May 2011, the private consulting group Policy & Economic Research Council (PERC)
published a study on credit report accuracy funded by the Consumer Data Industry Association
(CDIA). See Turner, Michael A., Robin Varghese, and Patrick D. Walker (2011). U.S. Consumer
Credit Reports: Measuring Accuracy and Dispute Impacts (hereinafter the “PERC Study”)
available at http://www.perc.net/wp-content/uploads/2013/09/DQreport.pdf. The PERC Study
used a methodology similar to the design of the 2012 FTC 319 Study and engaged consumers,
data furnishers, and CRAs. For a full discussion of the similarities and differences, please see
Appendix A of the 2012 FTC 319 Study.
11
VantageScores provided by the CRAs were used solely to generate a sample that was
representative of the national distribution of consumers with credit reports and credit scores.
However, credit score products generated by FICO are more commonly used by the majority of
lenders when making lending decisions. Thus, to determine whether dispute modifications
resulted in a credit score change, analysts at FICO scored the initial credit reports, generated
FICO scores, and rescored the reports with modifications. There are a number of differences
between VantageScore and FICO credit scores, the first of which is the different scales used by
the credit scoring models. VantageScores range from 500-999 and FICO credit scores range from
300 to 850. Overall, VantageScore and FICO score are highly correlated for an individual
consumer and the use of VantageScores to generate the sample of participants resulted in a
sample that was also representative of the FICO credit score distribution.
12
In addition to providing enough data to estimate the distribution of credit scores, the use of
a large random sample provided by the CRAs minimizes the likelihood that the CRA would be
able to identify a study participant during the dispute process.
13
For example, the response rate for consumers with a VantageScore between 500 and 519
4

set of participants developed, the VantageScores and major demographic characteristics
available (age, gender, and regional location via zip code) of the participant sample to date were
analyzed and compared to the distribution of characteristics in the sampling frame. 14 The
sampling was sequentially adjusted so that that the ultimate sample of approximately 1,000
participants would be representative in credit scores and in the stated demographics. 15 This
sampling strategy resulted in the most nationally representative research sample on credit scores
to date.
To accept the invitation to participate in the study, participants registered at a secure website
(through FICO) and gave permission for the contractor to draw their credit reports. The study
associates drew three credit reports and mailed copies to the consumer for the phone interview.
These credit reports were also saved securely at FICO for later analysis. Study associates
conducted a phone interview with the consumer where they reviewed all the information in each
of the three credit reports. If the consumer alleged no errors on any credit report, the study
associate conducted an “exit interview” to collect some basic financial and demographic
information about the consumer.
If the consumer alleged an error on a credit report, the study associate assessed whether the
alleged error met the “materiality standard.” In the simplest terms, an error is considered
“material” if it relates to information considered when generating a FICO credit score. 16 If the
error was material, the study associate prepared a dispute letter clearly stating the nature of the
error and how the information on the credit report should be changed in order to be accurate. The
study associate mailed the dispute letter to the participant, who amended it with their date of
birth, SSN, and signature before mailing the dispute letter to the relevant CRA. 17
At this point in the process, the study associate transmitted all of the disputed information to
FICO; FICO analysts then calculated a provisional revised FICO score assuming all disputed
information would be modified by the CRA. After a minimum of 8 weeks, the study associate
redrew all the credit reports that were disputed and assessed what modifications were made in
response to disputes. If no changes were made, the original FICO score was the relevant credit
was 2.2% and the response rate for consumers with a VantageScore in the range 960-980 was
6.7%. In addition to sending proportionally more invitation letters, the level of compensation
differed. Potential participants with VantageScores below the sampling frame average were
offered $75 to participate and those with above average VantageScores were offered $25 to
participate.
14
For more detail on the methods used, see FTC Statement of Work attached as Appendix B
to the 2012 FTC 319 Study.
15
There were a total of 10 mailing waves.
16
For a more detailed description of material errors, please see Section 2.3 in the 2012 FTC
319 Study.
17
The fact that the study associates prepared the dispute letter reduced the time cost to the
consumer of disputing, but did not signal to the CRAs that the particular consumer was part of
the FTC study on accuracy. The prepared dispute letter took a form similar to one available to all
consumers on the FTC website: http://www.consumer.ftc.gov/articles/0384-sample-letterdisputing-errors-your-credit-report.
5

score. If all disputed changes were made, the provisional revised FICO score was the relevant
credit score. In some cases, the CRA made some, but not all, of the requested modifications. In
these cases, the study associates transmitted the new information to FICO, who provided an
additional revised score. Thus, consumers identified and alleged errors by reviewing their own
credit reports, and then the actual FCRA dispute process was utilized to evaluate the allegations.
Using this process, we were able not only to assess the rate of alleged errors, but also the rate of
confirmed material errors and their impact on credit scores. 18 It is important to note that this
methodology mimics the experience of the consumer; thus, the research design does not reveal
whether the error is due to the data furnisher or the CRA.

1.3.2 Results of 2012 FTC 319 Accuracy Study
Please see the 2012 FTC 319 Study for a full discussion of all the results.
In the 2012 FTC 319 Study, we focus on providing error rates from the consumer perspective. 19
There are 1,001 participants who reviewed their credit reports with a study associate in order to
identify potential inaccuracies. Of the 1,001 consumers who participated, 262 consumers (26%)
allege potentially material errors on at least one credit report. The CRAs make some of the
alterations requested by most of the consumers; 206 participants (79% of those who file disputes)
experience a modification in response to filing a dispute.
Looking more closely at the changes in score associated with these modifications, we find that
120 consumers (12%) experience a score increase and 9 consumers (0.9%) experience a score
decrease once the alleged errors were modified. There is no established rule or threshold,
however, for classifying the significance of a credit score change as minor or major because the
impact of a change in score is dependent on the current score. For example, a 25-point change in
FICO score that keeps the consumer in a particular credit risk category may not have a large
impact on the person’s likelihood of receiving credit. On the other hand, a one- or two-point
change in credit score that moves a consumer from one risk tier to the next may have a large
impact on the consumer’s access to credit or the products and rates the consumer is able to
secure. We find 52 consumers (5%) have a score change that improves their ‘risk tier’
classification. 20 In other words, there may be as many as one in twenty consumers who have an
error on a credit report that may affect their terms or eligibility for credit if the error is not
18

In the 2012 FTC 319 Study, the phrase “confirmed material error” refers to material
information on a credit report that a consumer alleges to be erroneous in this study and is
modified as a result of the FCRA dispute process.
19
In contrast, the 2011 PERC Study provides statistics at the credit report level, which results
in a lower error rate. Because the consumer is the primary unit of analysis in the 2012 FTC 319
Study, we are able to provide reliable estimates of the proportion of American consumers who
would encounter material errors across their three credit reports. Considering that lenders often
use a composite of the consumer’s three reports and scores in making a credit decision, the
impact of material errors on consumers (rather than individual reports) is the focal point of the
study.
20
Lenders may use credit risk categories to separate consumers and offer different loan
products to consumers in different credit risk tiers.
6

identified, disputed, and modified. Given that 262 consumers identified potential errors, this
finding implies there is a 1 in 5 chance that a consumer who identifies an error and obtains a
correction may end up in a lower risk tier.
Because we track each item disputed by the consumer, the 2012 FTC 319 Study also presents the
rate at which we observe certain types of alleged errors. The most common types of alleged and
subsequently modified errors are errors in tradeline accounts (accounting for close to half of
alleged errors) and collections accounts (representing almost one-third of alleged errors). 21
Roughly 35% of the allegations regarding tradeline information is that the account is “not mine”
or does not belong to the consumer. The incidence is much higher for collections accounts
disputes, with over 80% of the disputes alleging the collections item does not belong to the
consumer.
It is also important to note that the 2012 FTC 319 Study characterizes errors as confirmed
material errors when the CRA modifies the credit report in response to the consumer dispute.
However, there are 56 consumers (5.6% of the participants) who file disputes and yet the CRA
makes no modification to their report. For the purpose of the analysis of the 2012 Report, these
consumers are not defined as having a confirmed material error. In addition, there are 109
consumers who had some, but not all, of the requested changes made to their reports. These
consumers who alleged potentially material errors, which were not confirmed through the initial
FCRA dispute process, may still have inaccurate items on their credit reports; however, we are
unable to verify the inaccuracy within the design of the 2012 Report. Thus, a non-negligible
number of consumers have disputes that could be characterized as unresolved at the conclusion
of the 2012 FTC 319 Study.

2
Changes within the Credit Reporting Industry Following
the 2012 FTC 319 Study
The 2012 FTC 319 Study was released to the public in the spring of 2013. 22 In the year
following the release of the FTC’s study on accuracy, the credit reporting industry took a number
of steps to continue to improve data accuracy. These industry-level efforts to focus on data
21

Tradelines are consumer accounts such as credit cards and store cards.
The National Consumer Law Center (NCLS) and U.S. PIRG, two consumer advocacy
groups, issued a joint press release regarding the 2012 FTC 319 Study. The statement lauded the
findings of the study, and urged Congress to confirm a Director for the Consumer Financial
Protection Bureau (CFPB) in order to remove uncertainty regarding the CFPB’s authority over
credit bureaus. See Press Release, New FTC Study Points To Much-Needed Reforms For Credit
Reporting Industry (February 2013), available at http://www.uspirg.org/news/usp/new-ftc-studypoints-much-needed-reforms-credit-reporting-industry. Richard Cordray was confirmed as the
first Director of the CFPB on July 16, 2013. See The White House Blog, Senate Confirms
Richard Cordray as Consumer Watchdog (July 2013), available at
http://www.whitehouse.gov/blog/2013/07/17/senate-confirms-richard-cordray-consumerwatchdog.
22

7

quality include improvements to education programs for consumers and changes to how the
industry and data furnishers handle dispute data. 23
First, Consumer Data Industry Association (CDIA) members launched a new version of the
eOscar system (the system through which consumer disputes are transmitted to data furnishers).
With the new version of eOscar, the documents that consumers submit to the CRAs in support of
their disputes are made available to lenders investigating the dispute. The new eOscar system
requires the lender to look at the supporting document(s) before completing its
investigation. Initially, this change to eOscar only applied to supporting documentation sent by
mail. By the end of 2013, CDIA members had redesigned their online dispute portals so that
consumers could upload validating documents online.
In August 2014, the CDIA launched a new online training resource for the Metro 2 Format (the
format for the data submitted to the CRAs by the data furnisher). Appendix E to Part 222 of the
Code of Federal Regulations states that data must be furnished in a standardized and clearly
understandable form and manner. However, the Consumer Financial Protection Bureau (CFPB)
conducted examinations of data furnishers and observed that “…deficiencies have resulted in
failure to communicate appropriate and accurate account information to credit bureaus…” The
CFPB further found “one or more instances in which a financial institution’s employees did not
have sufficient training or familiarity with the requirements of the FCRA to implement it
properly.” 24 The new eLearning system instituted by CDIA is an ongoing online resource for
questions about Metro 2 and includes a certificate training component so that lenders can train
their data furnishing teams. Further, CDIA has complemented this new Metro 2 training effort
with a new FCRA data furnisher compliance training system that focuses on the law and
regulations therein.
In addition to enhancing the ability of consumers to dispute and the way in which data is
transmitted, the CDIA focused on the disclosure of credit reports that consumers’ may receive
annually for free. Utilizing a grant from its nationwide consumer reporting agency members,
CDIA conducted a Public Service Announcement campaign to encourage consumers to obtain
their free credit reports. In October 2013, CDIA’s nationwide consumer reporting agency
members also redesigned the site through which consumers access the free credit report
disclosures, www.annualcreditreport.com. This redesign was based on several behavioral design
labs housed at major universities. After testing a variety of possible designs, the new website for
consumers to receive their annual three free credit reports is more effective both in terms of
consumers’ ability to complete requests for a free report and also in terms of accessing relevant
information about their rights, etc. One measure of the success of this effort is measured by the
66% increase in the number of users who now choose to read newly designed financial literacy
information found on the site.

23

Communication with Stuart Pratt, President & CEO at Consumer Data Industry
Association, 8/29/14. E-mail on file with the FTC.
24
Consumer Financial Protection Bureau (CFPB), Supervisory Highlights: Fall 2012,
available at: http://www.consumerfinance.gov/reports/supervisory-highlights-fall-2012/.
8

Overall, these efforts by the credit reporting industry focus on improving the dispute process so
that consumers’ disputes are investigated with supporting documents, improving the
transmission of data from data furnishers to the CRA, and improving the consumers’ knowledge
about their ability to review their credit reports. All of these efforts could be expected to improve
data quality and accuracy of credit reports. In addition, the individual CRAs may have taken
other steps to improve data accuracy following the release of the 2012 FTC 319 Study.

3

Follow-Up Study

The original 2012 FTC 319 Study followed participants through one round of the dispute process
and treated an alleged error as confirmed if the CRA made a modification of that item in
response to the initial dispute. The 2012 FTC 319 Study found that 80% of the consumers who
filed disputes had modifications made to their credit reports. Although this high rate of
modifications is a positive finding, one concern expressed by consumers and consumer advocacy
groups regarding the dispute process is whether the inaccurate information might reappear on the
credit report in the future. 25 The reappearance of negative information previously removed in
response to a consumer dispute is referred to as reinsertion. In addition to concerns regarding
reinsertion, there also remained a non-negligible number of consumers in the original study with
alleged inaccurate items that were not changed by the CRA.
In order to assess the likelihood of reinsertion as well as examine the degree to which alleged
inaccuracies remained unresolved for the consumer, the FTC extended the contract with the
UMSL contractor team to include a Follow-Up Study. The Follow-Up to the 2012 FTC 319
Accuracy Study involved re-drawing credit reports for a subset of the original participants and
contacting a subset of the participants who had alleged errors in the main study to complete a
follow-up interview.
Specifically, the goals of the Follow-Up Study were to provide information regarding reinsertion
of negative information, unresolved credit report disputes, and the nature of the unresolved
disputes. The next few subsections present tables from the Follow-Up Study. First, utilizing
redrawn credit reports, Section 3.1 provides the proportion of consumers who have information
reinserted into the credit reports following a dispute and the frequency of item types (e.g.,
tradeline, collections, duplicate accounts, etc.) that are reinserted into credit reports following a
consumer dispute. Next, Section 3.2 describes the sample of consumers who participate in the
Follow-Up Study interview. Section 3.3 presents the proportion of consumers who continue to
dispute an item after the disputed item is initially validated as accurate by the credit reporting
25

See Chi Chi Wu, Automated Injustice: How a Mechanized Dispute System Frustrates
Consumers Seeking to Fix Errors in their Credit Reports (National Consumer Law Center
Report January 2009) available at www.consumerlaw.org. This report describes one consumer
example (at p. 8) of reinsertion: “Occasionally, Equifax would delete one of false accounts from
Angela’s credit report, only to have the account show up again later.” One of the reform
recommendations from the NCLC report is for CRAs to improve the data furnishing system in
order to prevent reinsertion.
9

agency’s dispute process, as well as the proportion of participants who still believe the item is
inaccurate but have chosen not to dispute further (e.g., the dispute is abandoned because the
participant feels the dispute process is too time consuming or difficult). Finally, Section 3.4
illustrates the proportion of consumers who allege an account does not belong to them (i.e., “not
mine”) and whether the consumers later recollect that the account does belong to them.

3.1

Reinsertion of Negative Information

First, we examine the study sample for the possibility of negative information reinsertion.
Section 611(a)(5)(B) of the FCRA clearly outlines the rules regarding the reinsertion of negative
information that had been removed in response to a customer dispute.
(B) Requirements Relating to Reinsertion of Previously Deleted Material
(i)
Certification of accuracy of information. If any information is
deleted from a consumer’s file pursuant to subparagraph (A), the
information may not be reinserted in the file by the consumer
reporting agency unless the person who furnishes the information
certifies that the information is complete and accurate. 26
(ii)
Notice to consumer. If any information that has been deleted from
a consumer’s file pursuant to subparagraph (A) is reinserted in the
file, the consumer reporting agency shall notify the consumer of
the reinsertion in writing not later than 5 business days after the
reinsertion or, if authorized by the consumer for that purpose, by
any other means available to the agency.
(iii) Additional information. As part of, or in addition to, the notice
under clause (ii), a consumer reporting agency shall provide to a
consumer in writing not later than 5 business days after the date of
the reinsertion
(I)
a statement that the disputed information has been
reinserted;
(II)
the business name and address of any furnisher of
information contacted and the telephone number of
such furnisher, if reasonably available, or of any
furnisher of information that contacted the consumer
reporting agency, in connection with the reinsertion of
such information; and
(III) a notice that the consumer has the right to add a
statement to the consumer’s file disputing the accuracy
or completeness of the disputed information. 27

26

Section 611(a)(5)(A) states that if a CRA investigates a consumer dispute and finds that the
information is inaccurate, incomplete, or cannot be verified, then the CRA is required to
promptly delete or modify the information as appropriate, and promptly notify the furnisher of
that information that the information has been deleted or modified.
27
FCRA, Section 611(a)(5)(B).
10

A great deal of law enforcement and policy work addressed the issue of reinsertion in the mid1990’s. 28 Enforcement actions brought against CRAs were among the forces that led to the 1996
Amendments to the FCRA. Among other things, the 1996 Amendments require data furnishers
(who previously did not have such requirements) to delete, modify, or permanently block the
reporting of disputed information that was found to be inaccurate, thus reducing the likelihood of
negative information being reinserted. As a result of this legal requirement, we would expect
reinsertion to be relatively infrequent.
There is very little research on the frequency of reinsertion and previous analysis of reinsertion
has been based on consumer surveys. For example, in 2005 the GAO conducted a survey of
almost 1600 consumers to assess credit reporting literacy. 29 These consumers were asked a
multitude of questions regarding credit reporting, including questions on whether the consumer
had ever previously disputed inaccurate information, if the inaccurate information had been
removed, and if it was removed, whether the inaccurate information was later reinserted. Of the
18% of consumers who had disputed negative information, 69% claim that the inaccurate
information was removed in response to the dispute. Additionally, 13% of these consumers who
disputed and had negative information removed claimed that the inaccurate information was
reinserted.
This Follow-Up Study is the first study of reinsertion to examine whether previously disputed
and removed inaccurate information reappears on a consumer’s credit report by analyzing the
actual credit report and comparing it to a previous version. The 2012 FTC 319 Study provides a
unique opportunity to study reinsertion, given the large number of consumers who received
modifications following a dispute. In order to study reinsertion, the study associates redrew the
credit reports of any study participant who had a change made to their credit report following a
dispute. 30 There were 206 consumers who disputed and experienced a change to at least one item
on one of their credit reports in the 2012 FTC 319 Study. These 206 consumers sent 399 dispute
letters to the three CRAs. The contractor was successful in redrawing 393 of these disputed
credit reports for 202 consumers. 31
For each item that was disputed and modified by the credit reporting agency in 2011, the study
associates analyzed whether the negative information had reappeared on the consumer’s credit
report in 2012. After reviewing the redrawn credit reports to see if the previously modified
negative information was reinserted, the contractor identified two instances of reinsertion. In one
28

See, e.g., Equifax Credit Information Services, Inc. ,120 F.T.C. 577 (1995) (consent order)
(alleging, among other things, that the respondent failed to prevent the reappearance in consumer
reports of inaccurate or unverified information that had been previously deleted).
29
Government Accountability Office. CREDIT REPORTING LITERACY: Consumers
Understood the Basics but Could Benefit from Targeted Educational Efforts. March 2005,
available at http://www.gao.gov/assets/250/245667.pdf.
30
These credit reports were redrawn in the fall of 2012. The initial consumer interview and
dispute process occurred in early 2011.
31
The study associates were not able to redraw credit reports for four consumers due to
technical reasons (such as a bureau imposed freeze or a report with insufficient information to
generate a credit score).
11

instance, a previously removed collection item reappeared on a consumer’s credit report and the
balance of the collection item increased. This consumer’s credit score was impacted by the
reinsertion. The other instance of reinsertion involved an account that was disputed as “not
mine” and removed reappearing as a collection item when the credit report was redrawn. The
new collection item had no effect on this person’s credit score.
From the contractor report (at p. 4):
In one case involving a reinstatement (Case A), the consumer had originally
disputed a collection that had appeared on the report from just one of the three
bureaus. In 2011, the collection was removed as requested (along with a disputed
Inquiry). The effect of that would have been an increase of 31 points in the
original credit score (from 576 to 607, crossing one lending threshold, though
remaining between the scores from the other two bureaus). The collection
reappeared as an item in the 2012 report. (The collection balance also changed
from $487 to $817). Rescoring the original report again with the collection
replaced caused the credit score to drop to its original level. In the follow-up
interview, we determined:
1. The consumer was not notified that the disputed collection, previously
removed, had been reinstated.
2. The consumer does not understand why the collection was reinstated.
3. The consumer still does not accept this collection as his.
4. The consumer does not intend to pursue the issue further because he says
it is a waste of time and there is little chance that the bureau will correct
the file. His sentiments towards the credit-reporting industry were very
negative.
The other case (Case B) reported a charged-off “account not mine” involving
[Telecom Firm] in the dispute with two bureaus. It was removed from both
bureaus in 2011 as requested, but reappeared in one bureau in 2012 as a
collection item. It had no effect on the credit score. The consumer was not
informed and does not accept this. She intends to follow up directly with [Telecom
Firm].
Overall, reinsertion occurred for two out of the 202 consumers (1%) who originally disputed and
had modifications to their credit report. 32 However, framing the reinsertion rate relative to the
number of items disputed results in a much lower rate. Of the 1,561 items disputed in the 2012
FTC 319 Study where the outcome was known, there were 864 items that were modified by the
CRAs. The study associates were able to identify only two instances of reinsertion of negative
information previously modified, implying an item-level reinsertion rate of 0.2%. 33
32

These two instances of reinsertion occurred at different CRAs and for different item types
(collections item and tradeline item).
33
Recall that there were four consumers for whom the study associates were not able to
redraw credit reports due to technical reasons. Thus, the full reinsertion rate may be higher if
those four consumers also experienced reinsertion of any items previously modified by the
12

Given the efforts of law enforcement in the mid-1990’s and the resulting changes to the FCRA in
1996, we would not expect reinsertion to be pervasive. While a 1% reinsertion rate at the
consumer level is relatively small, extrapolating to the population of consumers with modified
disputes would imply a large number of consumers who face possible reinsertion. However,
reinsertion does not appear to be a systemic problem, as 99% of the consumers did not have their
modified information reinserted into their credit reports.
These findings underscore the need for consumers to regularly check their credit reports for
inaccuracies, even after a dispute is resolved in accordance with the consumer. These examples
of reinsertion also suggest that consumers may also find it beneficial to dispute the inaccurate
information with the data furnisher (e.g., The [Telecom Firm] in the second case above) in
addition to the CRAs. In addition, regulators and CRAs must remain vigilant that previously
removed negative items do not reappear on consumer credit reports.
It is also worthwhile to note that both consumers who experienced reinsertion of previously
removed negative information claim they were not informed that this information was reinserted
into their credit reports. Section 611(a)(5)(B)(ii) states that credit reporting agencies must notify
the consumer of the reinsertion in writing not later than 5 business days after the reinsertion.
Unfortunately, we cannot know with certainty that the CRAs did not provide notification. It is
possible that these consumers received notice in the mail but either did not recognize what the
notice meant, or recognized the notice but had forgotten by the time the study associate
questioned the consumers on the particular reinserted item. Despite the uncertainty regarding
consumer recollection about notification, the CRAs should review their notification process to
make sure they provide notifications to the relevant consumer in the case of reinsertion. We
discuss notification by CRAs more below.

3.2

Follow-Up Interview Sample

Of the 262 consumers who filed a dispute during the 2012 FTC 319 Study, 188 required a
“follow-up interview.” The subset of consumers requiring a “follow-up interview” includes any
consumer who had alleged an error that was not modified in the original dispute process, any
consumer who alleged an account did not belong to them (“not mine”) and any consumer who
appeared to have inaccurate information reinserted onto their credit report after previously being
modified by the CRAs. The contractor attempted to contact these eligible consumers by phone
for up to five attempts. 34 The same privacy protocols used in the 2012 FTC 319 Study were
utilized for the Follow-Up Study. 35 However, the contractor was not able to make contact with
CRAs.
34
Study associates attempted to reach the consumer on the phone since the original interview
had been conducted via phone. Study associates left voice messages when possible and
supplemented the calls with emails. Not surprisingly, there were many instances where the study
associate was not able to make contact with the participant and the participant was excluded
from this follow-up analysis. The Contractor Appendix provides the questions included in the
follow-up interview.
35
Privacy Impact Assessment for the Registration Web Site for the National Study of Credit
13

all the consumers who were eligible for follow-up interviews. Overall, the study contractor was
able to make contact with 135 consumers out of the original 262 consumers who filed a dispute
during the 2012 FTC 319 Study. Thus, the consumers who chose to participate in the follow-up
interview represent a sample of consumers who filed disputes.
In order to examine whether the follow-up participants are representative of the full sample of
disputants, we perform basic statistical tests comparing the follow-up participants to the
disputants who did not participate in the Follow-Up Study. 36 We find that the demographic
characteristics of the Follow-Up Study participants are significantly different from the
demographic characteristics of consumers who did not participate in the follow-up interview;
Follow-Up Study participants are more likely to be male, older, and a homeowner, as well as
have fewer children, and have higher self-assessed credit knowledge. Although the Follow-Up
Study consumers differ in their demographic characteristics, we do not find strong evidence that
the consumers’ credit report disputes are significantly different across follow-up participants and
non-follow-up participants. Specifically, there are not significant differences across the FollowUp Study participants and non-participants in terms of the number of accounts with errors
disputed, the number of changes made by the CRAs in response to the disputes, or the number of
alleged errors in public records, bankruptcy, inquiries, and credit utilization. 37 Thus, the
consumers who participated in the follow-up interview do not appear to be systematically
different on key credit report dimensions from those consumers with whom the contractor could
not make contact.

3.3

Unresolved Disputes

As noted above, a substantial number of participants alleged errors in the 2012 FTC 319 Study
that were not modified at all (56), or had some errors modified and some that were not modified
(109). It is possible that these individuals made a mistake in alleging the item was inaccurate.
Alternatively, it is possible that the CRA and the data furnisher have inaccurate information in
their records, and did not make any changes in response to the initial dispute. In this case, the
consumer may need to continue to dispute the inaccuracies or escalate the dispute.

Report Accuracy, October 2010. The document may be accessed at the FTC’s Web site:
http://www.ftc.gov/ftc/privacyimpactassessment.shtm.
36
The statistical test utilized was a two-sample, two-tailed t-test comparing the mean value in
the follow-up group to the mean value in the group that did not participate in the follow-up
interview. A p-value

For cases where changes were not made as requested, the FTC has asked us to inquire
whether participants understood why not and whether they pursued the matter further.
In your case, item … was not (fully) changed as you requested.
1. Did Equifax/Experian/Trans Union notify you regarding your dispute?
2. Did Equifax/Experian/Trans Union communicate the reason the change(s) were
not made?
3. Do you understand why not?
4. Do you accept this information as now correct?
If YES - Thanks for validating that, we'll record this in our final tallies to the FTC.
If NO - go to 5.
5. Have you pursued this further?
If YES - How ? (if dispute was filed get specific details);
What was the outcome?
If NO - Why Not?

2

One thing the FTC asked us to check is whether changes made in response to disputes in
2011 may have been undone.
In your case, it appears that the item pertaining to … that was … has reappeared as … .
1. Were you notified of this by Equifax/Experian/Trans Union?
2. Do you understand why this occurred?
3. Do you accept this information as now correct?
If YES - Thanks for validating that, we'll record this in our final tallies to the FTC.
If NO - You may, of course, file another dispute with the bureau.
4. With this information are you likely to do so?
If not, why not?

For cases where individuals reported information as not belonging to them the FTC is
trying to understand how the material could have gotten into the file.
In your case, you reported that … is not your account/does not apply to you.
1. Could it have belonged to a relative or to another person at your address?
if Yes, were you an authorized user or co-signer for the account?
2. Could it be yours but you don’t recognize it?
For example:
a. unrecognized name for a credit card,
b. unrecognized lender or reporting organization,
c. or, debt reported under the loan servicer or a different institution,
unknown debt reported by collection agency)
d. other

3

Thank you again for participating in the study and for helping to answer these follow-up
questions. The FTC’s report to Congress will be available at their website early next
year.

Contractor Appendix C – Statistical Tables

17 : 01 Tuesday, March 26, 2013

Table 1A -Frequencies of Responses to Whether Not-Mine Accounts Could Belong to Another Person Same Address
Based on Contacts with 51 of 78 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

II DNR II

NA

1

18

2

1

3
All

19

Bureau B

II Yes

No

8
II

II DNR II No II Yes

NA

1

7

18

6
II

5

1

14

1

1

29

2

Bureau C

23

II DNR II No II Yes

NA

3

3

18

9
II

2

1

14

1

1

23

4

20

6

1

14

1

1

29

1

1

17 : 01 Tuesday, March 26, 2013

Table 18- Percentages of Responses to Whether Not-Mine Accounts Could belong to Another Person Same Address
Based on Contacts with 51 of 78 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

66.7

2

12.5

3
All

37.3

II DNR II

Bureau B

No

29.6
II

II Yes
3.7

87.5

NA

II DNR II No II Yes

66.7

22.2
II

62.5

6.3

87.5

6.3

2.0

56.9

3.9

45.1

Bureau C

11 .1

37.5

NA

II DNR II No II Yes

66.7

33.3
II

25.0

6.3

87.5

6.3

2.0

45.1

7.8

39.2

75.0

6.3

87.5

6.3

2.0

56.9

2.0

2

17 : 0 1 Tuesday, March 26, 2 0 13

Table 2A -Frequencies of Responses to Whether The Person was an Authorized User on Not-Mine Accounts
Based on Contacts with 51 of 78 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

II DNR II No II POS II Yes

NA

1

18

7

r.----

2

II

1

3
All

Bureau B

19

II

6

II DNR II No II POS II Yes

NA
2

18

1

5

1

13

1

1

1

26

1

4

Bureau C

23

7
II

2
II

3

II DNR II

NA
18

9
II

2

1

13

1

1

1

23

1

3

20

II POS II Yes

No

II

5

1

1

13

1

1

1

27

1

2

3

17 : 0 1 Tuesday, March 26, 2 0 13

Table 28- Percentages of Responses to Whether The Person was an Authorized User on Not-Mine Accounts
Based on Contacts with 51 of 78 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

II DNR II No II POS II Yes

66.7

25.9

rr-

2
3
All

::=

II

12.5

37.3

Bureau B

II

75.0

NA

7.4

66.7

12.5

62.5

6.3

81.3

6.3

6.3

2.0

51.0

2.0

7.8

45.1

Bureau C

II DNR II No II POS II Yes
25.9
II

7.4
II

37.5

NA

II DNR II

66.7

81.3

6.3

6.3

2.0

45.1

2.0

5.9

39.2

II POS II Yes

33.3
II

25.0

6.3

No

II

62.5

12.5

6.3

81.3

6.3

6.3

2.0

52.9

2.0

3.9

4

17 : 01 Tuesday, March 26, 2013

Table 3A -Frequencies of Responses to Whether The Not-Mine Account Could have Been His or Hers
Based on Contacts with 51 of 78 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

II DNR II

NA

1

18

2

1

3
All

19

II

Bureau B

II Yes

No

II DNR II Mix II No II Yes

NA

8

1

18

6

1

5

1

11

4

1

25

6

Bureau C

2

6

1

18

· 11

2

1

2

10

5

18

7

II
II

1
23

1

II DNR II

NA

2

20

II Yes

No
6

3

5

1

1

10

5

1

21

9

II

5

17 : 01 Tuesday, March 26, 2013

Table 3B - Percentages of Responses to Whether The Not-Mine Account Could have Been His or Hers
Based on Contacts with 51 of 78 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

66.7

2

12.5

3
All

37.3

II DNR II
II

Bureau B

No

II Yes

NA

29.6

3.7

66.7

75.0

12.5

62.5

6.3

68.8

25.0

2.0

49.0

11.8

II DNR II Mix II No II Yes
22.2

3.7

66.7

· 11

25.0

12.5

25.0

62.5

31.3

35.3

13.7

II

2.0

NA

7.4
II

6.3
45.1

Bureau C

3.9

39.2

II DNR II

No

II Yes

22.2

11.1

62.5

12.5

6.3

62.5

31 .3

2.0

41.2

17.6

II

6

17 : 01 Tuesday, March 26, 2013

Table 4A - Frequencies of Responses to Whether Notified When Not All Changes Were Imposed as Requested
Based on Contacts with 122 of 181/ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

II DNR II

NA

Bureau B

II Yes

No

Bureau C

II DNR II No II Yes

NA

II DNR II No II Yes

NA

1

31

1

4

10

26

4

6

10

35

2

5

4

2

11

2

9

12

9

1

14

10

14

1

9

10

7

14

21

7

14

21

7

16

19

10

27

43

12

34

41

10

30

33

3
All

42

35

49

7

17 : 01 Tuesday, March 26, 2013

Table 48 - Percentages of Responses to Whether Notified When Not All Changes Were Imposed as Requested
Based on Contacts with 122 of 181/ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

II DNR II

Bureau B

No

II Yes

NA

Bureau C

II DNR II No II Yes

NA

II DNR II No II Yes

1

67.4

2.2

8.7

21 .7

56.5

8.7

13.0

21.7

76.1

4.3

10.9

8.7

2

32.4

5.9

26.5

35.3

26.5

2.9

41 .2

29.4

41.2

2.9

26.5

29.4

16.7

33.3

50.0

16.7

33.3

50.0

16.7

38.1

45.2

8.2

22.1

35.2

9.8

27.9

33.6

8.2

24.6

27.0

3
All

34.4

28.7

40.2

8

17 : 0 1 Tuesday, March 26, 2 0 13

Table 5A - Frequencies of Responses to Whether Given Reasons for Changes Not Made
Based on Contacts with 122 of 181/ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

II DNR II Mix II

NA

1
r.----

2

3
All

::==

31

1

11

1

42

Bureau B

II Yes

No

Bureau C

II DNR II No II Yes

NA

II DNR II Mix II

NA

9

5

26

4

10

6

36

2

1

14

7

9

1

19

5

14

1

7

2

24

9

7

23

12

9

3

47

21

12

52

23

35

50

II

II Yes

No

7

1

13

6

7

1

26

8

10

1

46

15

9

17:01 Tuesday , March 26 , 201 3

Table 58 - Percentages of Responses to Whether Given Reasons for Changes Not Made
Based on Contacts with 122 of 181/ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

II DNR II Mix II

67.4

2.2

32.4

2.9

Bureau B
No

II Yes

NA

Bureau C

II DNR II No II Yes

NA

II DNR II Mix II

19.6

10.9

56.5

8.7

21.7

13.0

78.3

4.3

2.9

41.2

20.6

26.5

2.9

55.9

14.7

41 .2

2.9

16.7

4 .8

57.1

21.4

16.7

54.8

28.6

7.4

2.5

38.5

17.2

9.8

42.6

18.9

rr-

2

3
All

::=

34.4

28.7

41 .0

II

No

II Yes

15.2

2.2

38.2

17.6

16.7

2.4

61.9

19.0

8.2

0.8

37.7

12.3

10

11

17:01 Tuesday, March 26, 2013

Table 6A - Frequencies of Responses to Whether Understands Why Changes Not Made
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

II DNR II Mix II

NA

31

1
r.----

2
3
All

::==

II

11
42

II

Bureau B

II Yes

No

II DNR II Mix II No II Yes

NA

9

6

26

19

4

9

1

4

27

10

1

4

55

20

Bureau C

35

II

II

II DNR II Mix II No II Yes

NA

12

8

36

21

4

14

1

4

25

12

1

4

58

24

50

II

II

8

2

17

3

1

3

28

10

1

3

53

15

17:01 Tuesday , March 26 , 201 3

Table 68 - Percentages of Responses to Whether Understands Why Changes Not Made
Based on Contacts with 122 of 181 Individuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

II DNR II Mix II

67.4
rr-

2
3
All

::=

II

32.4

34.4

II

Bureau B
No

II Yes

NA

19.6

13.0

56.5

55.9

11.8

26.5

2.4

9.5

64.3

23.8

0.8

3.3

45.1

16.4

28.7

Bureau C

II DNR II Mix II No II Yes
II

II

NA

26.1

17.4

78.3

61 .8

11.8

41.2

2.4

9.5

59.5

28.6

0.8

3.3

47.5

19.7

41.0

II DNR II Mix II No II Yes
II

II

17.4

4.3

50.0

8.8

2.4

7.1

66.7

23.8

0.8

2.5

43.4

12.3

12

17:01 Tuesday, March 26, 2013

Table 7A- Frequencies of Responses to Whether Accepts Changes Not Made as Reasonable
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

31

2

11

3
All

42

Bureau B

II DNR II Mix II No I Yes
II

II

II DNR II Mix II No II POS II Yes

NA

9

6

26

17

6

9

1

3

27

11

1

3

53

23

Bureau C

35

9
II

II

II

21

NA

11

36

4

14

1

4

24

1

12

1

4

54

1

27

50

II DNR II Mix II No II Yes
II

II

7

3

15

5

1

3

27

11

1

3

49

19

13

17:01 Tuesday , March 26 , 201 3

Table 78- Percentages of Responses to Whether Accepts Changes Not Made as Reasonable
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

67.4

2

32.4

3
All

34.4

Bureau B

II DNR II Mix II No I Yes
II

II

NA

19.6

13.0

56.5

50.0

17.6

26.5

2.4

7.1

64.3

26.2

0.8

2.5

43.4

18.9

28.7

Bureau C

II DNR II Mix II No II POS II Yes
II

II

NA

19.6

23.9

78.3

61.8

11.8

41 .2

2.4

9.5

57.1

2.4

28.6

0.8

3.3

44.3

0.8

22.1

41 .0

II DNR II Mix II No II Yes
II

II

15.2

6.5

44.1

14.7

2.4

7.1

64.3

26.2

0.8

2.5

40.2

15.6

14

17:01 Tuesday , March 26 , 201 3

Table BA - Frequencies of Responses to Whether Pursuing Matters Further
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

1

37

2

17

3

12

All

66

Bureau B

II Mix II No I Yes

NA

II Mix II No II POS II Yes

3

6

37

5

12

5

13

11

2

14

14

13

1

15

2

29

25

63

1

31

II

Bureau C

2
2

NA

II Mix II No II POS II Yes

4

39

1

4

8

19

13

12

2

16

25

70

3

25

5

2
2

8

12
2

22

15

17:01 Tuesday , March 26 , 201 3

Table 88 - Percentages of Responses to Whether Pursuing Matters Further
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A
NA

Bureau B

II Mix II No I Yes

Bureau C

NA

II Mix II No II POS II Yes

NA

8.7

84.8

23.5

55.9

31 .0

28.6

4.8

38.1

20.5

57.4

2.5

20.5

1

80.4

6.5

13.0

80.4

10.9

2

50.0

35.3

14.7

38.2

32.4

3

28.6

4.8

33.3

33.3

31 .0

2.4

35.7

All

54.1

1.6

23.8

20.5

51 .6

0.8

25.4

5.9

1.6

II Mix II No II POS II Yes
2.2

8.7
14.7

4.3
5.9

23.5
28.6

1.6

18.0

16

17:01 Tuesday, March 26, 2013

Table 9A - Frequencies of Responses to Why Not Pursuing Matters Funher
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

No Time

NA

Not
Hurting
Score

Not
Looking
for Credit

Not
Important

Little
Hope of
Change

Maybe
Correct

Too Much
Effort

Mixed
Reasons

1

43

2

22

2

1

26

4

2

2

3

1

1

1

2

91

6

3

2

13

1

1

3

2

Too Much
Effort

Mixed
Reasons

3

3
7

2

~ '------=

All

Number
of
Bureaus
Disputed

Bureau B

No Time

NA

Not
Hurting
Score

Not
Looking
for Credit

1

41

1

2

21

2

1

26

4

2

88

7

3

3

Not
Important

Little
Hope of
Change

Maybe
Correct

2

1

1

8

1

2

4

1

1

1

1

2

14

3

1

2

2

Too Much
Effort

Mixed
Reasons

1

~ '------=

All

Number
of
Bureaus
Disputed

Bureau C

NA

No Time

Not
Hurting
Score

Not
Looking
for Credit

Not
Important

Little
Hope of
Change

1

1

2

3

1

Maybe
Correct

1

41

1

2

27

1

25

4

2

2

5

1

1

1

1

93

6

2

3

9

4

1

3

1

3

2

~ '------=

All

17

17:01 Tuesday , March 26 , 201 3

Table 98 - Percentages of Responses to Why Not Pursuing Matters Funher
Based on Contacts with 122 of 1811ndividuals
(NA means the issue or question is not relevant for the case at that bureau)

Number
of
Bureaus
Disputed

Bureau A

NA

3

Not
Looking
for Credit

93.5

1
2

No Time

Not
Hurting
Score

::==

Not
Important

Little
Hope of
Change

Maybe
Correct

Too Much
Effort

Mixed
Reasons

6.5

64.7

5.9

2.9

20.6

5.9

61 .9

9.5

4.8

4.8

7.1

2.4

2.4

2.4

4.8

74.6

4.9

2.5

1.6

10.7

0.8

0.8

2.5

1.6

Not
Important

Little
Hope of
Change

Maybe
Correct

Too Much
Effort

Mixed
Reasons

4.3

2.2

23.5

2.9

~~

All

Number
of
Bureaus
Disputed

Bureau B

NA

1
2

3

::==

No Time

Not
Hurting
Score

Not
Looking
for Credit

89.1

2.2

2.2

61 .8

5.9

2.9

61 .9

9.5

4.8

4.8

9.5

2.4

2.4

2.4

2.4

72.1

5.7

2.5

1.6

11.5

2.5

0.8

1.6

1.6

Maybe
Correct

Too Much
Effort

Mixed
Reasons

2.9

~~

All

Number
of
Bureaus
Disputed

Bureau C

NA

1
2

3

::==

No Time

Not
Hurting
Score

Not
Looking
for Credit

Not
Important

Little
Hope of
Change

2.2

2.2

4.3

8.8

2.9

89.1

2.2

79.4

2.9

59.5

9.5

4.8

4.8

11.9

2.4

2.4

2.4

2.4

76.2

4.9

1.6

2.5

7.4

3.3

0.8

2.5

0.8

5.9

~~

All

18

16 : 48 Wednesday, April 10, 2 0 13

Table 10A - Frequencies of Responses to Whether Not-Mine Accounts Could Belong to Another Person Same Address
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

II

DNR

II Yes II All

No

Bureau A

1

29

2

32

Bureau B

1

23

4

28

Bureau C

1

29

1

31

All

3

81

7

91

1

16 : 48 Wednesday, Apri l 10 , 2013

Table 108 - Percentages of Responses to Whether Not-Mine Accounts Could belong to Another Person Same Address
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

DNR

II

No

II Yes II All

Bureau A

3.1

90.6

6.3

100.0

Bureau B

3.6

82.1

14.3

100.0

Bureau C

3.2

93.5

3.2

100.0

All

3.3

89.0

7.7

100.0

2

16 : 48 Wednesday, April 10, 2 0 13

Table 11A- Frequencies of Responses to Whether The Person was an Authorized User on Not-Mine Accounts
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

II

DNR

II POS II Yes II

No

All

Bureau A

1

26

1

4

32

Bureau B

1

23

1

3

28

Bureau C

1

27

1

2

31

All

3

76

3

9

91

3

16 : 48 Wednesday, Apri l 10 , 2013

Table 118- Percentages of Responses to Whether The Person was an Authorized User on Not-Mine Accounts
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

DNR

II

No

II POS II Yes II All

Bureau A

3.1

81.3

3.1

12.5

100.0

Bureau B

3.6

82.1

3.6

10.7

100.0

Bureau C

3.2

87.1

3.2

6.5

100.0

All

3.3

83.5

3.3

9.9

100.0

4

16 : 48 Wednesday, April 10, 2 0 13

Table 12A- Frequencies of Responses to Whether The Not-Mine Account Could have Been His or Hers
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

Bureau

II Mix II No II Yes II

DNR

Bureau A

1

Bureau B

1

Bureau C

1

All

3

2
2

All

25

6

32

18

7

28

21

9

31

64

22

91

5

16 : 48 Wednesday, April 10, 2013

Table 128- Percentages of Responses to Whether The Not-Mine Account Could have Been His or Hers
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

Bureau

DNR

Bureau A

3.1

Bureau B

3.6

Bureau C

3.2

All

3.3

II Mix II No II Yes II
7.1

2.2

All

78.1

18.8

100.0

64.3

25.0

100.0

67.7

29.0

100.0

70.3

24.2

100.0

6

16 : 48 Wednesday, April 10, 2 0 13

Table 13A- Frequencies of Responses to Whether Notified When Not All Changes Were Imposed as Requested
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

Bureau

DNR

II

II Yes II All

No

Bureau A

10

27

43

80

Bureau B

12

34

41

87

Bureau C

10

30

33

73

All

32

91

117

240

7

16 : 48 Wednesday, Apri l 10 , 2 0 13

Table 138- Percentages of Responses to Whether Notified When Not All Changes Were Imposed as Requested
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

Bureau

DNR

II

No

II Yes II All

Bureau A

12.5

33.8

53.8

100.0

Bureau B

13.8

39.1

47.1

100.0

Bureau C

13.7

41.1

45.2

100.0

All

13.3

37.9

48.8

100.0

8

16 : 48 Wednesday, April 10, 2013

Table 14A - Frequencies of Responses to Whether Given Reasons for Changes Not Made
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

II Mix II No II Yes II

DNR

Bureau A

9

Bureau B

12

Bureau C

10

All

31

3

All

47

21

80

52

23

87

1

46

15

72

4

145

59

239

9

16:48 Wednesday, April 10, 201 3

Table 148- Percentages of Responses to Whether Given Reasons for Changes Not Made
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

DNR

Bureau A

11.3

Bureau B

13.8

Bureau C

13.9

All

13.0

II Mix II No II Yes II
3.8

All

58.8

26.3

100.0

59.8

26.4

100.0

1.4

63.9

20.8

100.0

1.7

60.7

24.7

100.0

10

16 : 48 Wednesd ay, April 10, 2013

Table 15A- Frequencies of Responses to Whether Understands Why Changes Not Made
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

II Mix II No II Yes II

DNR

All

Bureau A

1

4

55

20

80

Bureau B

1

4

58

24

87

Bureau C

1

3

53

15

72

All

3

11

166

59

239

11

16 : 48 Wednesd ay , April 1 0, 201 3

Table 158- Percentages of Responses to Whether Understands Why Changes Not Made
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

DNR

II Mix II No II Yes II

All

Bureau A

1.3

5.0

68.8

25.0

100.0

Bureau B

1.1

4.6

66.7

27.6

100.0

Bureau C

1.4

4.2

73.6

20.8

100.0

All

1.3

4.6

69.5

24.7

100.0

12

16:48 Wednesday, April 10, 2013

Table 16A - Frequencies of Responses to Whether Accepts Changes Not Made as Reasonable
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

II Mix II No II POS II Yes II All

DNR

Bureau A

1

3

53

Bureau B

1

4

54

Bureau C

1

3

49

All

3

10

156

1
1

23

80

27

87

19

72

69

239

13

16:48 Wednesday, April 10, 2013

Table 168 - Percentages of Responses to Whether Accepts Changes Not Made as Reasonable
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

II Mix II No II POS II Yes II All

Bureau

DNR

Bureau A

1.3

3.8

66.3

Bureau B

1.1

4.6

62.1

Bureau C

1.4

4.2

68.1

All

1.3

4.2

65.3

1.1

0.4

28.8

100.0

31 .0

100.0

26.4

100.0

28.9

100.0

14

16 : 48 Wednesd ay , April 1 0, 2013

Table 17A- Frequencies of Responses to Whether Pursuing Matters Further
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

Bureau

II No II POS II Yes II All

Mix

Bureau A

2

29

25

56

Bureau B

1

31

2

25

59

Bureau C

3

25

2

22

52

All

6

85

4

72

167

15

16:48 Wednesday, April 10, 201 3

Table 178- Percentages of Responses to Whether Pursuing Matters Further
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Bureau

Mix

II No II POS II Yes II All

Bureau A

3.6

51.8

44.6

100.0

Bureau B

1.7

52.5

3.4

42.4

100.0

Bureau C

5.8

48.1

3.8

42.3

100.0

All

3.6

50.9

2.4

43.1

100.0

16

16 : 48 Wednesd ay, April 10, 2013

Table 18A- Frequencies of Responses to Why Not Pursuing Matters Further
(Ignoring instances where the issue or question is not relevant for the case at that bureau)

Bureau
No Time

Not
Hurting
Score

Not
Looking
Not
for Credit Important

Little
Hope of
Change

Maybe
Correct

Too Much
Effort

Mixed
Reasons

All

Bureau A

6

3

2

13

1

1

3

2

31

Bureau B

7

3

2

14

3

1

2

2

34

Bureau C

6

2

3

9

4

1

3

1

29

All

19

8

7

36

8

3

8

5

94

17

16:48 Wednesday , April 10, 2013

Table 188- Percentages of Responses to Why Not Pursuing Matters Further
(Ignoring instances where the issue or question is not relevant for the case at that bureau)
Not
Looking
Not
for Credit Important

Little
Hope of
Change

Maybe
Correct

Too Much
Effort

Mixed
Reasons

No Time

Not
Hurting
Score

Bureau A

19.4

9.7

6.5

41.9

3.2

3.2

9.7

6.5

100.0

Bureau B

20.6

8.8

5.9

41.2

8.8

2.9

5.9

5.9

100.0

Bureau C

20.7

6.9

10.3

31.0

13.8

3.4

10.3

3.4

100.0

All

20.2

8.5

7.4

38.3

8.5

3.2

8.5

5.3

100.0

Bureau

All

18

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Aftc%3A553b20a47cfa8a9b. Public record. Not legal advice.