FR 2025-07400

The document is a notice from the Federal Trade Commission (FTC) requesting public comments on extending the current Paperwork Reduction Act (PRA) clearance. This involves data collection mandates related to the Duties of Consumer Reporting Agencies rule, implemented in conjunction with the Consumer Financial Protection Bureau (CFPB). This rule ensures that consumers have access to one free credit report per year from consumer reporting agencies.

General Summary

The Federal Trade Commission, alongside the Consumer Financial Protection Bureau, wants to maintain its ability to collect information under a rule that allows consumers to request a free credit report annually. The purpose of extending the paperwork approval is so that this consumer benefit can continue unimpeded. They are inviting public feedback on this extension by May 30, 2025.

Significant Issues and Concerns

One notable issue is the reliance on legal jargon and specific references to legal codes that can be challenging for the general public to understand. References like 15 U.S.C. 1681a(p) and other technical statutes may confuse those not versed in legal language, making it difficult for individuals to fully grasp the notice's details.

Additionally, the document fails to explain how the estimated labor costs and burden hours were calculated, raising potential concerns about the transparency and accuracy of these figures. These estimates are crucial for understanding the financial and operational impact of the information collection requirement.

There's also a focus on specific types of consumer reporting agencies without explaining why these particular ones are prioritized, which might create a perception of bias or favoritism. Furthermore, although there is guidance on what not to include in public comments (like sensitive personal information), the document does not sufficiently address how to securely submit comments, which could lead to privacy risks.

Impact on the Public

Broadly, the extension of this clearance impacts consumers by continuing their ability to access free credit reports, a vital tool for monitoring personal creditworthiness and identifying potential identity theft. However, the complexity of the document may prevent public engagement or informed commentary due to the language and lack of explanatory context.

Impact on Specific Stakeholders

For consumer reporting agencies, this extension involves maintaining systems and processes required by the rule, including a centralized platform for consumers to request their credit reports. This can pose a financial and operational burden, though it is essential for regulatory compliance.

Consumers stand to benefit significantly from the extension by preserving their right to a free annual credit report, aiding them in financial planning and credit management. Meanwhile, the CFPB and FTC share enforcement responsibilities, ensuring that consumer rights in credit reporting continue to be protected.

In conclusion, while the FTC's initiative to extend the PRA clearance supports consumer rights, it also highlights the need for clearer communication and secure channels for public feedback. Addressing these concerns could enhance public understanding and participation in this important regulatory process.

The document outlines a request by the Federal Trade Commission (FTC) for an extension of a current Paperwork Reduction Act (PRA) clearance, which includes specific financial elements related to the enforcement of a rule by the Consumer Financial Protection Bureau (CFPB). The financial references primarily concern the burden associated with the rule's enforcement and operation.

Summary of Financial Allocations

In reviewing the document's financial components, it notes two primary monetary figures associated with the FTC's role in implementing the consumer reporting rules. The total burden for the FTC, when shared with the CFPB, is outlined as 121,818 hours, with financial implications including $3,135,077 in associated labor costs and $4,010,500 in capital/non-labor costs. These figures represent the resources required by the FTC to meet the requirements of the rule.

The labor cost figure appears to have been adjusted from a previous estimate of $2,973,410, showing an increase based on updated data from the Bureau of Labor Statistics, indicating an effort to maintain current and realistic budgetary expectations.

Relation to Identified Issues

In relation to the issues identified within the document, the presentation of financial allocations lacks transparency in explaining how these figures were calculated. Without a clear methodology, the accuracy or validity of these estimates could be questioned by those calling for more precise data. This could lead to skepticism regarding the allocation and management of resources associated with the rule's execution.

Moreover, the document references specific consumer reporting agencies affected by these rules but does not elucidate why these particular agencies are prioritized. This lack of clarity might cause concerns among other businesses or entities involved, who may question why their burden or costs are not similarly highlighted or explained.

Overall, clear communication concerning financial allocations and their derived methodologies is essential in alleviating concerns or misunderstandings and ensuring accountability in the use of government resources. Adjustments in the labor cost figures imply responsiveness to economic changes or updates in labor market conditions, though without contextual explanations, public trust in these processes might not be fully achieved.