Sandra Andelo - 2

Document ID: OCC-2008-0022-0003
Document Type: Public Submission
Agency: Comptroller Of The Currency
Received Date: August 05 2009, at 10:22 AM Eastern Daylight Time
Date Posted: August 6 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: July 1 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: August 31 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a020be
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This is comment on Proposed Rule

Guidelines for Furnishers of Information to Consumer Reporting Agencies

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The FCRA should include protection for consumers against extension of charge off dates which many creditors do. This negatively affects the consumer's credit worthiness and credit score. For example, Capital One is notorious for this, a credit card is charged off in July 2004. Capital One instead of leaving this date alone, reports as follows Charge Off as of Aug 2009, Charge Off as of July 2009, Charge Off as of June 2009, Charge Off as of May 2009, Charge off as of April 2009, Charge Offf March 2009, Charge Off July 2004. For all intents and purposes their disclosure in the Credit Report is making it seem as if this accolunt recently went into collectio when it did not, this in turn is negatively affecting the consumer's score because the different dates of charge are generating recencies on the "LATES" which in turn has a negative affect on the scoring model. This needs to be stopped and penalized since it does not paint a true picture of the consumer's credit worthiness.