Agency Information Collection Activities; Proposed Collection; Comment Request, 35191-35195 [E9-17147]

Agencies

• FEDERAL TRADE COMMISSION

[Federal Register Volume 74, Number 137 (Monday, July 20, 2009)]
[Notices]
[Pages 35191-35195]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-17147]


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FEDERAL TRADE COMMISSION


Agency Information Collection Activities; Proposed Collection; 
Comment Request

AGENCY: Federal Trade Commission (``FTC'' or ``Commission'').

ACTION: Notice.

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SUMMARY: The FTC plans to conduct a national study of the accuracy of 
consumer reports in connection with Section 319 of the Fair and 
Accurate Credit Transactions Act of 2003, Pub. L.108-159 (2003). This 
study is a follow-up to the Commission's two previous

[[Page 35192]]

pilot studies.\1\ Before gathering this information, the FTC is seeking 
public comment on its proposed study. The FTC will consider comments 
before it submits a request for Office of Management and Budget (OMB) 
review under the Paperwork Reduction Act (PRA).
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    \1\Reports to Congress Under Sections 318 and 319 of the Fair 
and Accurate Credit Transactions Act of 2003, Federal Trade 
Commission, December 2006 and 2008. The reports may be accessed at 
the FTC's Web site. December 2006 Report: (https://www.ftc.gov/reports/FACTACT/FACT_Act_Report_2006.pdf); December 2008 Report: 
(https://www.ftc.gov/opa/2008/12/factareport.shtm).

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DATES: Comments must be received on or before September 18, 2009.

ADDRESSES: Interested parties are invited to submit written comments 
electronically or in paper form. Comments should refer to ``National 
Accuracy Study: Paperwork Comment (FTC file no. P044804)'' to 
facilitate the organization of the comments. Please note that your 
comment--including your name and your state--will be placed on the 
public record of this proceeding, including on the publicly accessible 
FTC Website, at (https://www.ftc.gov/os/publiccomments.shtm).
    Because comments will be made public, they should not include any 
sensitive personal information, such as an individual's Social Security 
Number; date of birth; driver's license number or other state 
identification number, or foreign country equivalent; passport number; 
financial account number; or credit or debit card number. Comments also 
should not include any sensitive health information, such as medical 
records or other individually identifiable health information. In 
addition, comments should not include any ``[t]rade secret or any 
commercial or financial information which is obtained from any person 
and which is privileged or confidential. . . .,'' as provided in 
Section 6(f) of the Federal Trade Commission Act (``FTC Act''), 15 
U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2). Comments 
containing material for which confidential treatment is requested must 
be filed in paper form, must be clearly labeled ``Confidential,'' and 
must comply with FTC Rule 4.9(c), 16 CFR 4.9(c).\2\
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    \2\ The comment must be accompanied by an explicit request for 
confidential treatment, including the factual and legal basis for 
the request, and must identify the specific portions of the comment 
to be withheld from the public record. The request will be granted 
or denied by the Commission's General Counsel, consistent with 
applicable law and the public interest. See FTC Rule 4.9(c), 16 CFR 
4.9(c).
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    Because paper mail addressed to the FTC is subject to delay due to 
heightened security screening, please consider submitting your comments 
in electronic form. Comments filed in electronic form should be 
submitted by using the following web link: (https://secure.commentworks.com/ftc-FACTA319study) (and following the 
instructions on the web-based form). To ensure that the Commission 
considers an electronic comment, you must file it on the web-based form 
at the web link (https://secure.commentworks.com/ftc-FACTA319study). If 
this Notice appears at (https://www.regulations.gov/search/index.jsp), 
you may also file an electronic comment through that website. The 
Commission will consider all comments that regulations.gov forwards to 
it. You may also visit the FTC Website at https://www.ftc.gov to read 
the Notice and the news release describing it.
    A comment filed in paper form should include the ``National 
Accuracy Study: Paperwork Comment (FTC file no. P044804)'' reference 
both in the text and on the envelope, and should be mailed or delivered 
to the following address: Federal Trade Commission, Office of the 
Secretary, Room H-135 (Annex J), 600 Pennsylvania Avenue, NW, 
Washington, DC 20580. The FTC is requesting that any comment filed in 
paper form be sent by courier or overnight service, if possible, 
because U.S. postal mail in the Washington area and at the Commission 
is subject to delay due to heightened security precautions.
    The FTC Act and other laws the Commission administers permit the 
collection of public comments to consider and use in this proceeding as 
appropriate. The Commission will consider all timely and responsive 
public comments that it receives, whether filed in paper or electronic 
form. Comments received will be available to the public on the FTC 
Website, to the extent practicable, at (https://www.ftc.gov/os/publiccomments.shtm). As a matter of discretion, the Commission makes 
every effort to remove home contact information for individuals from 
the public comments it receives before placing those comments on the 
FTC Website. More information, including routine uses permitted by the 
Privacy Act, may be found in the FTC's privacy policy, at (https://www.ftc.gov/ftc/privacy.shtm).

FOR FURTHER INFORMATION CONTACT: Peter Vander Nat, Economist, (202) 
326-3518, Federal Trade Commission, Bureau of Economics.

SUPPLEMENTARY INFORMATION: Section 319 of the Fair and Accurate Credit 
Transactions Act of 2003 (``FACT Act'' or the ``Act''), Pub. L.108-159 
(2003) requires the FTC to study the accuracy and completeness of 
information in consumers' credit reports and to consider methods for 
improving the accuracy and completeness of such information. Section 
319 of the Act also requires the Commission to issue a series of 
biennial reports to Congress over a period of eleven years. The first 
report was submitted to Congress in December 2004.\3\ The second report 
was submitted to Congress in December 2006 (``December 2006 Report''), 
describing the results of a pilot study. The third report was submitted 
in December 2008 (``December 2008 Report''), describing the results of 
a second pilot study.
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    \3\ Report to Congress Under Sections 318 and 319 of the Fair 
and Accurate Credit Transactions Act of 2003, Federal Trade 
Commission, December 2004. The December 2004 Report is available at 
(https://www.ftc.gov/reports/facta/041209factarpt.pdf).
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    In July 2005, OMB approved the FTC's request to conduct a pilot 
study to evaluate the feasibility of a methodology that involves direct 
review by consumers of the information in their credit reports (OMB 
Control Number 3084-0133),\4\ and the FTC conducted that pilot study in 
2005-2006. As explained in the December 2006 report, FTC staff 
concluded that it was necessary to conduct a second pilot study to 
evaluate additional design elements prior to carrying out a nationwide 
survey. Upon receiving further OMB approval (reinstatement of Control 
No. 3084-0133), the FTC conducted the second pilot study in 2007-2008. 
The FTC's pilot studies used small samples and did not rely on the 
selection of a nationally representative sample of credit reports; 
accordingly, no statistical projections were made. The FTC now plans to 
conduct a national study of the accuracy of consumer reports in 
connection with Section 319 of the Fair and Accurate Credit 
Transactions Act of 2003, Pub. L.108-159 (2003). This study is a 
follow-up to the Commission's two previous pilot studies.
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    \4\ See 70 FR 24583 (May 10, 2005) for discussion of the initial 
pilot study and related public comments.
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Proposed Information Collection Activities

    Under the PRA, 44 U.S.C. 3501-3521, federal agencies must obtain 
approval from OMB for each collection of information they conduct or 
sponsor. ``Collection of information'' means agency requests or 
requirements that members of the public submit reports, keep records, 
or provide information to a third party. 44 U.S.C. Sec.  3502(3), 5 CFR

[[Page 35193]]

Sec.  1320.3(c). Because the number of entities affected by the 
Commission's requests will exceed ten, the Commission plans to seek OMB 
clearance under the PRA. As required by Sec.  3506(c)(2)(A) of the PRA, 
the FTC is providing this opportunity for public comment before 
requesting that OMB grant the clearance for the proposed information 
collection.
    The FTC invites comments on: (1) whether the proposed collections 
of information are necessary for the proper performance of the 
functions of the FTC, including whether the information will have 
practical utility; (2) the accuracy of the agency's estimate of the 
burden of the proposed collection of information, including the 
validity of the methodology and assumptions used; (3) ways to enhance 
the quality, utility, and clarity of the information to be collected; 
and (4) ways to minimize the burden of the collection of information on 
those who are to respond, including through the use of appropriate 
automated, electronic, mechanical, or other technological collection 
techniques or other forms of information technology (e.g., permitting 
electronic submission of responses). More generally, the FTC invites 
comment on the various design elements for a national study set forth 
below. All comments should be filed as prescribed in the ADDRESSES 
section above, and must be received on or before September 18, 2009.

1. Description of the Collection of Information and Proposed Use

A. Initial Pilot Study (2005-2006)
    The goal of the initial pilot study was to assess the feasibility 
of directly engaging consumers in an in-depth review of their credit 
reports for the purpose of identifying alleged material errors and 
channeling such errors through the Fair Credit Report Act (``FCRA'') 
dispute resolution process. The FTC's contractor for the initial pilot 
study--a research team comprised of members from the Center for 
Business and Industrial Studies (University of Missouri-St Louis), 
Georgetown University Credit Research Center, and the Fair Isaac 
Corporation--engaged 30 randomly selected participants in an in-depth 
review of their credit reports. Study participants obtained their 
credit reports and credit scores \5\ from each of the three nationwide 
consumer reporting agencies (Equifax, Experian, TransUnion--
hereinafter, the ``CRAs''). The contractor reviewed these credit 
reports with the participants and after an evaluation of alleged errors 
for materiality by the research team, consumers were asked to channel 
disputed information through the FCRA dispute resolution process.\6\
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    \5\ A credit score is a numerical summary of the information in 
a credit report and is designed to be predictive of the risk of 
default. Credit scores are created by proprietary formulas that 
render the following result: the higher the credit score, the lower 
the risk of default. The contractor in the first and second pilot 
studies employed (and the proposed national study expects to employ) 
a score that is commonly used in credit reporting, namely a FICO 
score.
    \6\ The FCRA dispute resolution process involves the review of 
disputed items by data furnishers and CRAs. The formal dispute 
process renders a specific outcome for each alleged error. By direct 
instruction of the data furnisher, the following outcomes may occur: 
delete the item, change or modify the item (specifying the change), 
or maintain the item as originally reported. A CRA may also delete a 
disputed item due to expiration of the statutory time frame (the 
FCRA limits the process to 30 days, but the time may be extended to 
45 days if a consumer submits relevant information during the 30-day 
period). These possible actions are tracked by a form called 
``Online Solution for Complete and Accurate Reporting'' (e-OSCAR) 
that is used by CRAs for resolving FCRA disputes. A consumer may 
also dispute information directly with a data furnisher, as provided 
for by FCRA 623(a)(8). 15 U.S.C.1681s-2(a)(8). (See also, Federal 
Trade Commission and Board of Governors of the Federal Reserve 
System, Report to Congress on the Fair Credit Reporting Act Dispute 
Process, August 2006. The report is available at (https://www.ftc.gov/os/comments/fcradispute/P044808fcradisputeprocessreporttocongress.pdf).
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    The first pilot study demonstrated the general feasibility of the 
consumer interview methodology, but also revealed several challenges 
for a national study.\7\ Challenges include identifying methods for 
achieving a more representative sampling frame, increasing the response 
rates, and easing the burden of completing the study. Compared to the 
national average for credit scores, consumers with relatively low 
scores were under-represented. Also, the majority of participants who 
alleged errors on their credit reports and indicated that they would 
file a dispute did not follow through with their stated intention to 
file. In consideration of these and other matters, the FTC conducted a 
follow-up pilot study.
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    \7\ The FTC's December 2006 Report to Congress contains a more 
detailed review of the study and its results.
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B. The Second Pilot Study (2007-2008)
    The second pilot study combined successful elements from the first 
pilot with new procedures designed to overcome shortcomings of the 
first pilot.
    Through a variety of recruitment channels, 4,232 people were 
invited to participate. Multiple recruitment methods were employed and 
these were useful in identifying differences in response rates and 
credit scores of the respondents across various methods of recruitment. 
Of the 4,232 individuals contacted, 128 (3%) became participants. The 
contractor \8\ helped participants obtain their 3 credit reports and 
conducted an in-depth review of the reports with each participant. The 
contractor also helped the participants to identify alleged 
inaccuracies and gave advice on the difference between a small 
inaccuracy and a material error that is likely to affect a credit 
score. Specific criteria for materiality were developed in consultation 
with Fair Isaac's analyst on the research team.\9\ If the consumer 
alleged a material error, the individual was encouraged to file a 
formal FCRA dispute so as to obtain a review of the challenged items by 
data furnishers and CRAs. The contractor prepared a dispute letter for 
any consumer who wanted to file and allege an error, material or not 
(as the FCRA permits a consumer to dispute any credit report 
information that the person believes to be inaccurate).
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    \8\ Due to the similarity in design (i.e., second pilot was 
constructed as a follow-up to first) the FTC employed the same 
contractor.
    \9\ December 2008 Report (at 3). The contractor used the 
following criteria for materiality: the consumer had a credit score 
less than 760 (a cutoff widely used to identify consumers with 
lowest credit risk and for extending credit on most favorable terms) 
AND the consumer alleged an error regarding any of the following 
matters: (i) negative items (such as late payments); (ii) public 
derogatories (such as bankruptcy); (iii) accounts sent to 
collection; (iv) number of inquiries for new credit; (v) outstanding 
balances not attributable to normal monthly reporting variation; 
(vi) accounts on the report not belonging to the person who is the 
subject of the report; or (vii) duplicate entries of the same 
information (e.g., late payments or outstanding obligations) that 
were double-counted in the reported summaries of such items. To 
enhance the efficiency of the study process, the stated criteria 
modify somewhat the procedure used in the first pilot study 
(contractor's report on second pilot study at 27). In the proposed 
national study, we do not intend to use any cutoff score for 
materiality, but plan to retain the stated categories as indicating 
a dispute material to creditworthiness.
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    Regarding the results of the study, 88 of the 128 participants 
(69%) found no errors in their credit reports. Of the 40 participants 
who alleged one or more errors that they wanted to dispute, 15 (or 12% 
of the 128) alleged a material error. For 7 of these latter cases, the 
FCRA dispute process rendered credit report changes that were made 
fully in keeping with all of the consumer's allegations.\10\
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    \10\ Other cases (i.e., some of the consumer's allegations were 
confirmed while other allegations were denied) are summarized in the 
December 2008 Report (at 2 & 8).
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    As noted above, the second pilot study (like the first) used a 
small sample and no statistical projections were made. Accordingly, no 
extensive statistical summaries were needed, nor were any given, in the 
FTC's report on the study. The primary purpose of the pilot studies was 
to refine the expert-

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assisted survey approach for studying credit report information, in 
preparation for a national study.
    The second pilot study confirmed the importance of having the 
contractor prepare dispute letters for consumers. This was not done in 
the first pilot study. In the first pilot study, only 1 of the 3 
participants who alleged material errors on their credit reports filed 
a dispute. In the follow-up pilot study, all 15 of the participants who 
alleged material errors on their credit reports received dispute 
letters from the contractor, and the outcomes of these disputes are 
known for 12 of them. This is a significant improvement over the first 
pilot study.
    As noted above, multiple recruitment methods were used to identify 
differences in response rates and in credit scores of respondents 
across various methods of recruitment. The second pilot study confirmed 
the difficulties of obtaining adequate numbers of participants with 
below-average credit scores. Purely random sampling of potential 
participants yielded too few actual participants with low credit 
scores.\11\ A weighted random sampling approach, whereby more 
invitations were extended to groups of consumers who were likely to 
have lower credit scores, produced a sample closer to national 
norms.\12\
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    \11\Table III of the December 2008 Report (at 9).
    \12\Table 9 of the contractor's report (appendix to the December 
2008 Report).
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    The second pilot study indicated that it would be feasible to base 
a measure of the accuracy of credit report information on confirmed 
material errors via the FCRA dispute process. Whenever it appeared that 
a consumer's credit score could be affected by ``correcting'' an 
alleged material error, the contractor marked the credit reports (the 
frozen files) \13\ with explanations of the discrepancies and sent 
copies of the marked reports to Fair Isaac for rescoring. If, via the 
FCRA dispute process, changes were subsequently made by CRAs and 
lenders in keeping with the consumer's allegations, these changed items 
were then designated as confirmed material errors. We then rescore the 
frozen file to quantify the impact of the confirmed error(s) on the 
consumer's credit score. The difference between the rescore of the 
frozen file and the original score is a meaningful measure of the 
impact of inaccurate credit report information. We intend to use this 
type of methodology in a national study.\14\
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    \13\ The files are called ``frozen'' because no new credit 
information was added to the consumer's original credit reports 
obtained in the study; any rescoring would thus apply only to 
potential changes or actual changes that were directly related to 
the contractor's review.
    \14\ Certain limitations regarding this methodology are 
discussed in the December 2008 Report (at 3 & 4). Yet, use of the 
FCRA dispute process appears to be the only feasible way of 
performing a nationwide survey, in view of the enormous difficulty 
and cost of attempting to ascertain the ultimate accuracy regarding 
alleged errors.
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    As a final point of this summary of the pilot studies, the 
relatively low response rate (i.e., approximately 3% of the individuals 
contacted became participants) raises concern for the design of a 
national study regarding a potential response bias. This matter is 
addressed below.
C. Proposed National Study
    The proposed national study seeks to use a large representative 
sample of credit reports so that we may draw inferences, up to a 
certain level of statistical confidence, about the accuracy of credit 
reports in general. The need to employ a representative sample makes 
the initial steps of the proposed study different from the methodology 
of the second pilot study; in other respects, the methodologies of the 
two studies are largely the same. Our goal is to obtain approximately 
1,000 participants who as a group display a diversity on credit scores 
and on major demographic characteristics in line with national norms.
    The relevant population for the study is comprised of adult members 
of households who have credit histories with Equifax, Experian, and/or 
TransUnion. To study these credit histories we propose, as a first 
step, to obtain a very large random sample (with an order of magnitude 
of 200,000 names) from one of the consumer reporting agencies in order 
to determine a set of individuals selected for possible contact (the 
``SPC list'').\15\ From this SPC list, FTC staff will draw a further 
and considerably smaller random sample (e.g., 10% sample) of 
individuals selected for contact (the ``SC list'').
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    \15\ The information in this sample, which would include names, 
addresses, and credit scores, is to be obtained under applicable law 
and protected from disclosure by, e.g., Exemption 6 of the Freedom 
of Information Act, 5 U.S.C. 552. That information, as well as any 
credit reports that individual participants give permission to be 
analyzed for the study, will be maintained and used by the FTC and 
its contractors subject to appropriate information security 
procedures and safeguards (e.g., maintaining credit-related data 
separately from personal identifying information, requiring the 
FTC's contractors to execute confidentiality agreements, and 
limiting access to those FTC and contractor staff who have a need to 
work with the data). As noted above, the study methodology is also 
designed to prevent disclosure of any individual's participation in 
the study to any credit reporting agency.
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    There are several reasons for this two-step process. First, the 
vast majority of the names on the SPC list will not be sent invitations 
to participate and thus helps ensure that no CRA will know who is 
participating in the study. Further, using the SC list, we plan to send 
proportionally more invitation letters to individuals with lower credit 
scores. Use of this weighted random sampling approach is designed to 
obtain an ultimate set of participants having credit scores 
(specifically, the lower scores) in line with national norms, as 
suggested by the results of the second pilot study.\16\
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    \16\ December 2008 Report (at 9 &10).
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    After some substantial set of individuals have agreed to join the 
study (300 - 400 people), we will have an initial sample. This sample 
will be compared with the larger SPC list on credit scores and 
geographic diversity. Statistically significant differences between 
this initial sample and the larger SPC list would reflect the impact of 
non-participation. From this information, we can selectively draw 
individuals from the SC list in an effort to compensate for these 
differences as necessary.
    As a further check on a potential bias in the decision to 
participate, we plan to obtain anonymized (redacted) credit reports 
(and related credit scores) \17\ for the entire class of non-
respondents, i.e., all the people from the SC list who choose not to 
participate. Using the redacted reports and related scores we can 
determine, for example, whether non-respondents had significantly 
different credit scores or significantly different credit histories 
from those who agreed to participate.
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    \17\ These credit reports and scores will be generated and 
maintained without name, address or personal identifiers other than 
ID numbers assigned by the study.
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    Upon completion of the study, we will have a database with detailed 
demographic information about the participants, the type and quantity 
of alleged material errors on their credit reports, the type and 
quantity of confirmed material errors via the FCRA dispute process, and 
the impact of any such confirmed errors on the participants' credit 
scores.\18\ Further, by

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analyzing the redacted credit reports and related scores of the non-
respondents, we obtain a final check on the degree to which the 
enhanced procedures were effective in achieving a nationally 
representative sample of credit reports.
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    \18\ Using the methodology of the pilot studies, we expect to 
obtain a variety of alleged errors: incorrect report of late 
payment; multiple reports of an account with late payment; paid 
account reported as delinquent; closed account reported as 
delinquent; incorrect financial account reported (``not mine''); 
incorrect collection balance; incorrect collection account reported; 
multiple reports of an account in bankruptcy; chapter 7 accounts 
discharged but reported as delinquent, as well as further types of 
alleged errors. For these same categories we can also tabulate 
confirmed material errors via the FCRA dispute process. As explained 
above, the rescoring of the frozen files will then provide the 
impact of any confirmed errors on the participants' credit scores.
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2. Estimated Hours Burden

    Consumer participation in the proposed national study would involve 
an initial preparation for the in-depth interview and time spent by 
participants to understand, review, and if deemed necessary, dispute 
information in their credit reports. Invitation letters will be sent in 
progressive waves in order to obtain approximately 1,000 participants. 
The individuals who receive these letters are drawn from the SC list 
discussed above and will be asked to go directly to a designated Web 
site for enrollment if they wish to participate; registration is 
expected to take at most 15 minutes per participant.\19\ The 
registration process thus comes to approximately 250 hours (reckoned at 
1/4 hour for each of 1,000 consumers).
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    \19\ At the registration Web site, a person may take the time to 
read several disclosures, including a privacy disclosure and an 
outline of the various steps of the study that every participant 
agrees to undertake. The consumer is then asked to enter basic 
contact information (e.g., name, address, telephone number, best 
time to be contacted further about the study) and to enter an 
electronic signature certifying the consumer's consent to 
participate in the study. For those who may not have Internet access 
to register, the contractor would also have a procedure to mail the 
appropriate disclosures and study steps to the respondent and then 
receive back enrolment information and the consumer's signed consent 
in paper form.
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    For the purpose of calculating burden under the PRA regarding the 
review process of the credit reports, FTC staff submits the following 
estimates that are based on the contractor's experience with the second 
pilot study. Some participants prepare thoroughly in advance of the in-
depth interview of their credit reports. In such situations, even 
complicated reports may generally be finished under 30 minutes. Other 
consumers may not find time for significant preparation in advance of 
the in-depth review, and in such cases the interview could take up to 
an hour. The participants in the second pilot study reported taking an 
average of 69 minutes (median 53 minutes) to prepare for the interview, 
with 90% taking between 10 and 180 minutes. The interviews themselves 
took an average of 19 minutes (median 15 minutes) with 90% taking 
between 5 and 45 minutes. Overall, the average combined time for 
preparation and the interview was about 90 minutes (1.5 hours). For a 
national study involving 1,000 consumers, FTC staff thus estimates the 
burden hours for the review process to be approximately 1,500 hours 
(1,000 consumers x 1.5 hours). Further adding on the time spent for the 
registration process (0.25 hours per participant), the total burden 
hours come to approximately 1,750 hours.

3. Estimated Cost Burden

    The cost per consumer for their participation should be negligible. 
Participation is voluntary and it will not require any start-up or 
capital expenditure. There is no labor time expenditure beyond the 1.75 
hours per consumer estimated above. Participants may receive an 
honorarium to compensate them for their time. The amount will be 
determined by FTC staff in consultation with the contractor according 
to an analysis of customary procedures and a consideration of response 
rates within key categories, such as, response rates for consumers with 
impaired credit. As with the pilot studies, participants will not pay 
for their credit reports or credit scores.

Willard Tom,
General Counsel
[FR Doc. E9-17147 Filed 7-17-09: 8:45 am]
BILLING CODE: 6750 -01-S