The Center for Survivor Agency and Justice and the National Consumer Law Center petitioned the Consumer Financial Protection Bureau to open rulemaking under the Fair Credit Reporting Act (FCRA) to protect victims of coerced debt. The letter petitions for four major rule changes:
● The CFPB should modify the definition of “identity theft” to include “without effective
consent” to provide relief for victims of coerced debt and specify what constitutes
effective consent.
● The CFPB should modify the definition of “identity theft report” to reflect the modified
definition of “identity theft.”
● The CFPB should allow the modified definition of “identity theft” to enable victims of
coerced debt to utilize the block of information resulting from identity theft.
● The CFPB should clarify that no CRA, including specialty CRAs, can refuse to block
information under 15 U.S.C. §1681c-2(c)(1)(C) if the consumer is a victim of coerced
debt.
Read the full petition here.