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CBA Comment Letter re RFI on Consumers’ Experience with Free Access to Credit Scores
Consumer Financial Protection Bureau
Attention: Office of Financial Education
1700 G Street NW
Washington, D.C. 20552
Re: Request for Information Regarding Consumers’ Experience with Free Access to Credit Scores
Docket No. CFPB-2017-0037
Dear Sir or Madam,
The American Bankers Association and Consumer Bankers Association (collectively, the Associations) are pleased to submit our comments to the Bureau of Consumer Financial Protection (Bureau) in response to its request for information regarding consumers’ experience with free access to credit scores. The purpose of the request for information is to learn more about the experiences of consumers, companies, nonprofits, and others with regard to consumer access to free credit scores and to identify educational content that the Bureau or others could develop to increase consumers’ understanding of credit scores and credit reports. The request invites general comments as well as responses to specific questions.
Our comments briefly discuss the Bureau’s findings in its recent report, The Consumer Credit Card Market, about free access to credit scores through card issuers and other financial institutions. We recommend that the Bureau provide guidance on how institutions may educate consumers about credit scores without creating compliance risk, and guidance that the Bureau could apply to its own educational efforts.
It is clear from The Consumer Credit Card Market, published December 13, 2017, that the Bureau understands and has access to details about banks’ practices and experiences related to offering free credit scores to customers and non-customers. For example, based on its mass market card issuer survey, the Bureau found that most card issuers “provided some portion of their general purpose cardholders with online or mobile access to their credit scores” and that “over 50 million accounts accessed their credit scores at least once” in 2016. It also found that with regard to credit scores available through general purpose credit cards, that “nearly one-quarter of all general purpose accounts accessed their scores at least once during the year” and that there “was sharp growth in both eligibility and uptake from 2015 to 2016, around 35% and around 40%, respectively.” The report also noted that, in addition to offering free credit scores to credit card customers, many financial institutions are also offering free credit score access to their auto loan, student loan, mortgage, or online banking customers and that as of April, 2017, Fair Isaac Company reported that over 100 financial institutions were providing free credit score access to more than 200 million customer accounts. Thus, it is clear that consumers have broad access to free credit scores through banks and other financial institutions.
The Bureau asks in question five of its request for information whether credit score providers provide educational information about credit scores. Many banks providing free credit scores also offer varying types of educational information, such as FAQs explaining credit scores generally and top factors influencing customers’ scores.
 The American Bankers Association is the voice of the nation’s $17 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2 million people, safeguard $13 trillion in deposits and extend more than $9 trillion in loans.
 The Consumer Bankers Association is the only national trade focused exclusively on retail banking. Established in 1919, the association is now a leading voice in the banking industry and Washington, representing members who employ nearly two million Americans, extend roughly $3 trillion in consumer loans, and provide $270 billion in small business loans.
 Bureau of Consumer Financial Protection, The Consumer Credit Market (Dec. 2017).
 Id. at 176.
 Id. at 175.