We commend the FTC for issuing the proposed rule, much of which we strongly support. We also appreciate that the FTC is proposing to amend the Free Annual File Disclosures Rule to minimize confusion and exploitation of consumers attempting to access to their free annual credit report. We also commend the FTC for recognizing that
consumer reporting agencies (CRAs) use deceptive and confusing advertising to trick consumers into purchasing goods or services – such as credit monitoring services – that the consumers were not intending to buy. The proposed amendments are a good first cut at restricting abusive advertising practices and we generally support them. We offer the following comments.