February 21, 2012

Richard Cordray, Director

Bureau of Consumer Financial Protection

1500 Pennsylvania Avenue N.W.

Washington, DC 20220

Re:         Fair Credit Reporting (Regulation V)

Docket No. CFPB-2011-0029; RIN 3170-AA06

Dear Mr. Cordray:

The Alternative Banking group of Occupy Wall Street[1] submits this comment letter in response to the above-mentioned interim final rule establishing a new Regulation V (Fair Credit Reporting), 12 C.F.R. part 1022.

As a preliminary matter, we recognize that the instant interim final rule only reflects the transfer of authority over rulemaking under the Fair Credit Reporting Act (“FCRA”) between federal agencies, and does not impose new substantive obligations.  Even so, the Dodd-Frank Act transferred rulemaking authority for most provisions of the Fair Credit Reporting Act to the Bureau of Consumer Financial Protection (“Bureau”).  In issuing a purely procedural interim final rule, the Bureau has given up an opportunity to craft new regulations that could have furthered the interests of consumers nationwide.  

A mere transfer of authority from agency to agency will not serve the interests of the American public.  We write this letter to urge the Bureau to consider adopting substantive reforms to the current FCRA-related regulations in the coming months.  Below we propose a few key suggestions that the Bureau should consider during its deliberations for further regulation.

The CFPB should centrally manage the credit scoring system, instead of simply allowing private credit bureaus to control vital financial data that affects almost all Americans.  Credit data is highly valueable and consumer can reasonable government oversight over such data.  The following are some of our suggestions for reform:

The current credit reporting and scoring system enables the financial exploitation of millions of Americans.  The poor, immigrants, the elderly and other disadvantaged groups are particularly vulnerable.  We urge the CFPB to fulfill its statutory mandate by implementing bold new measures that overhaul and transform the credit scoring system such that it becomes more fair and equitable.

Thank you.

Sincerely,                        

/s/                                

OWS Alternative Banking                        

Occupy Wall Street - Alternative Banking

http://www.nycga.net/groups/alternative-banking/


[1] Alternative Banking (“AB”) is a group within the New York-based Occupy Wall Street (“OWS”) protest movement.  This letter represents the opinion of our group’s members, and does not represent the viewpoints of OWS as a whole.  AB seeks to explore and, if possible, establish alternative banking systems that might replace the current system.  AB also seeks to broadly understand and educate people about the current financial system, as well as come up with short and long term plans to improve it.