Consumer Credit Reporting: Assessing Accuracy and Compliance (House Hearing)
Summary
Transcript of the House Committee on Financial Services Subcommittee on Oversight and Investigations virtual hearing Consumer Credit Reporting: Assessing Accuracy and Compliance, convened May 26, 2021 during the 117th Congress, First Session, published as Serial No. 117-27 (GPO 45-079). Subcommittee Chairman Al Green presided with Ranking Member Andy Barr. Witnesses were Chi Chi Wu of the National Consumer Law Center, Beverly Anderson of Equifax Inc., Sandy Anderson of Experian North America, John Danaher of TransUnion, and Rebecca E. Kuehn of Hudson Cook, LLP testifying on behalf of the Consumer Data Industry Association.
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“Consumer Credit Reporting: Assessing Accuracy and Compliance (House Hearing).”
Original at www.govinfo.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/consumer-credit-reporting-assessing-accuracy-and-compliance-1c9d89ed0d/
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CONSUMER CREDIT REPORTING: ASSESSING
ACCURACY AND COMPLIANCE
VIRTUAL HEARING
BEFORE THE
SUBCOMMITTEE ON OVERSIGHT
AND INVESTIGATIONS
OF THE
COMMITTEE ON FINANCIAL SERVICES
U.S. HOUSE OF REPRESENTATIVES
ONE HUNDRED SEVENTEENTH CONGRESS
FIRST SESSION
MAY 26, 2021
Printed for the use of the Committee on Financial Services
Serial No. 117–27
(
U.S. GOVERNMENT PUBLISHING OFFICE
45–079 PDF WASHINGTON : 2021
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HOUSE COMMITTEE ON FINANCIAL SERVICES
MAXINE WATERS, California, Chairwoman
CAROLYN B. MALONEY, New York PATRICK MCHENRY, North Carolina,
NYDIA M. VELÁZQUEZ, New York Ranking Member
BRAD SHERMAN, California FRANK D. LUCAS, Oklahoma
GREGORY W. MEEKS, New York BILL POSEY, Florida
DAVID SCOTT, Georgia BLAINE LUETKEMEYER, Missouri
AL GREEN, Texas BILL HUIZENGA, Michigan
EMANUEL CLEAVER, Missouri STEVE STIVERS, Ohio
ED PERLMUTTER, Colorado ANN WAGNER, Missouri
JIM A. HIMES, Connecticut ANDY BARR, Kentucky
BILL FOSTER, Illinois ROGER WILLIAMS, Texas
JOYCE BEATTY, Ohio FRENCH HILL, Arkansas
JUAN VARGAS, California TOM EMMER, Minnesota
JOSH GOTTHEIMER, New Jersey LEE M. ZELDIN, New York
VICENTE GONZALEZ, Texas BARRY LOUDERMILK, Georgia
AL LAWSON, Florida ALEXANDER X. MOONEY, West Virginia
MICHAEL SAN NICOLAS, Guam WARREN DAVIDSON, Ohio
CINDY AXNE, Iowa TED BUDD, North Carolina
SEAN CASTEN, Illinois DAVID KUSTOFF, Tennessee
AYANNA PRESSLEY, Massachusetts TREY HOLLINGSWORTH, Indiana
RITCHIE TORRES, New York ANTHONY GONZALEZ, Ohio
STEPHEN F. LYNCH, Massachusetts JOHN ROSE, Tennessee
ALMA ADAMS, North Carolina BRYAN STEIL, Wisconsin
RASHIDA TLAIB, Michigan LANCE GOODEN, Texas
MADELEINE DEAN, Pennsylvania WILLIAM TIMMONS, South Carolina
ALEXANDRIA OCASIO-CORTEZ, New York VAN TAYLOR, Texas
JESÚS ‘‘CHUY’’ GARCIA, Illinois
SYLVIA GARCIA, Texas
NIKEMA WILLIAMS, Georgia
JAKE AUCHINCLOSS, Massachusetts
CHARLA OUERTATANI, Staff Director
(II)
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SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS
AL GREEN, Texas Chairman
EMANUEL CLEAVER, Missouri ANDY BARR, Kentucky, Ranking Member
ALMA ADAMS, North Carolina BARRY LOUDERMILK, Georgia
RASHIDA TLAIB, Michigan ALEXANDER X. MOONEY, West Virginia
JESÚS ‘‘CHUY’’ GARCIA, Illinois DAVID KUSTOFF, Tennessee
SYLVIA GARCIA, Texas WILLIAM TIMMONS, South Carolina, Vice
NIKEMA WILLIAMS, Georgia Ranking Member
(III)
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CONTENTS
Page
Hearing held on:
May 26, 2021 ..................................................................................................... 1
Appendix:
May 26, 2021 ..................................................................................................... 35
WITNESSES
WEDNESDAY, MAY 26, 2021
Anderson, Beverly, President, Global Consumer Solutions, Equifax Inc. ........... 7
Anderson, Sandy, Senior Vice President, Operations, Experian North Amer-
ica .......................................................................................................................... 9
Danaher, John, Executive Vice President, Consumer Interactive, TransUnion 10
Kuehn, Rebecca E., Partner, Hudson Cook, LLP, on behalf of the Consumer
Data Industry Association (CDIA) ...................................................................... 12
Wu, Chi Chi, Staff Attorney, National Consumer Law Center (NCLC) ............. 5
APPENDIX
Prepared statements:
Anderson, Beverly ............................................................................................ 36
Anderson, Sandy ............................................................................................... 43
Danaher, John, ................................................................................................. 48
Kuehn, Rebecca E. ............................................................................................ 53
Wu, Chi Chi ...................................................................................................... 71
ADDITIONAL MATERIAL SUBMITTED FOR THE RECORD
Green, Hon. Al:
Written statement of the Consumer First Coalition ..................................... 95
Student Borrower Protection Center report entitled, ‘‘Big Data & Big
Errors’’ ........................................................................................................... 97
Garcia, Hon. Sylvia:
CFPB Complaint Bulletin ................................................................................ 125
Mooney, Hon. Alexander X.:
Poverty Solutions, University of Michigan report entitled, ‘‘Auto Insur-
ance and Economic Mobility in Michigan: A Cycle of Poverty’’ ................ 139
Waters, Hon. Maxine:
Written responses to questions for the record submitted to Beverly Ander-
son .................................................................................................................. 145
Written responses to questions for the record submitted to Sandy Ander-
son .................................................................................................................. 149
Written responses to questions for the record submitted to John Danaher 153
(V)
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CONSUMER CREDIT REPORTING: ASSESSING
ACCURACY AND COMPLIANCE
Wednesday, May 26, 2021
U.S. HOUSE OF REPRESENTATIVES,
SUBCOMMITTEE ON OVERSIGHT
AND INVESTIGATIONS,
COMMITTEE ON FINANCIAL SERVICES,
Washington, D.C.
The subcommittee met, pursuant to notice, at 12:02 p.m., via
Webex, Hon. Al Green [chairman of the subcommittee] presiding.
Members present: Representatives Green, Adams, Tlaib, Garcia
of Illinois, Garcia of Texas, Williams of Georgia; Barr, Loudermilk,
Mooney, Kustoff, and Timmons.
Ex officio present: Representative Waters.
Also present: Representative Gottheimer.
Chairman GREEN. The Oversight and Investigations Sub-
committee will come to order.
Without objection, the Chair is authorized to declare a recess of
the subcommittee at any time. Also, without objection, members of
the full Financial Services Committee who are not members of this
subcommittee are authorized to participate in today’s hearing.
As a reminder, I ask all Members to keep themselves muted
when they are not being recognized by the Chair, to minimize dis-
turbances while Members are asking questions of our witnesses.
The staff has been instructed not to mute Members except where
a Member is not being recognized by the Chair and there is inad-
vertent background noise.
Members are reminded that all House rules relating to order and
decorum apply to this remote hearing. Members are also reminded
that they may participate in only one remote proceeding at a time.
If you are participating today, please keep your camera on, and if
you choose to attend a different remote proceeding, please turn
your camera off. If Members wish to be recognized during the hear-
ing, please identify yourself by name to facilitate recognition by the
Chair.
The title of today’s hearing is, ‘‘Consumer Credit Reporting: As-
sessing Accuracy and Compliance.’’
I now recognize myself for 3 minutes to give an opening state-
ment.
It is my honor to convene this hearing styled, ‘‘Consumer Credit
Reporting: Assessing Accuracy and Compliance.’’ This hearing will
examine the role of the three national credit regulatory agencies,
I will call them NCRAs, in the consumer credit reporting system
that affects the lives of virtually every adult in the United States.
(1)
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2
Other than assessing credit, employment, housing, insurance, or
even utilities, the information provided by the major NCRAs has
the power to either open or foreclose a vast array of opportunities
that undergird economic security and social justice for consumers.
Yet once again, in 2020, consumers complained to the Consumer
Financial Protection Bureau (CFPB) about NCRA reporting more
than any other subject, outpacing complaints about credit repair,
debt collectors, mortgage servicers, credit cards, and bank accounts;
and surpassing complaints about predatory lenders, payday loans,
title loans, and usury.
The number of NCRA-related complaints in 2020 was over
319,000, nearly double the number in 2019. So many, in fact, that
for the first time, the CFPB will be issuing a separate supple-
mental report to Congress dedicated to this class of complaints
alone. While this trend alone calls for oversight, the Coronavirus
Aid, Relief, and Economic Security (CARES) Act imposed new pro-
tections for consumers with respect to credit reporting. Hence, this
hearing will provide a timely window into the degree of compliance
by the NCRAs with CARES Act mandates and whether additional
protections are needed.
I look forward to hearing from today’s witnesses about what is
causing the increased level of complaints, whether rising complaint
levels are likely to continue, what has been done and what remains
to be done to address the elevated levels of complaints, the poten-
tial benefits afforded by alternatives such as a Federal credit bu-
reau as proposed by President Biden, whether comprehensive re-
forms are needed, and whether consumers need more control over
their data.
I would like to thank the staff for the outstanding work that they
have done to help facilitate this hearing. I am grateful to the Chair
of the full Financial Services Committee, the Honorable Maxine
Waters, for all of the effort and energy that she puts into all of
these hearings, and moving us forward.
And, finally, I want to thank the witnesses again for appearing
today, and my colleagues who are with us as well. I thank all of
you. And at this time, I am going to recognize the ranking member
of the subcommittee, Mr. Barr, for his 5-minute opening statement.
Mr. BARR. Thank you, Mr. Chairman. I appreciate you holding
this hearing today, and thank you to our witnesses for appearing
before the subcommittee. I look forward to your testimony.
The allocation of credit is the lifeblood of the American economy.
Lenders, insurers, and other financial firms rely on accurate credit
reports to reflect the potential risk of a customer, and consumers
expect that their credit reports are fair, and appropriately reflect
their financial histories to ensure that they may access financial
products at competitive prices.
Mechanisms exist for consumers to file a complaint or to dispute
an inaccuracy in their credit report. The Fair Credit Reporting Act
(FCRA) directs the CFPB to submit an annual report about com-
plaints to Congress. In the most recent report, the CFPB stated
that prior to COVID-19, the average number of complaints was ap-
proximately 300,000 per year, but in 2020, there were approxi-
mately 542,300 complaints, a 54-percent increase from 2019.
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3
I look forward to learning more today from our witnesses about
the potential causes for an increase in complaints and what the
credit reporting agencies are doing to address them.
In March of last year, Congress acted to ensure that consumer
credit histories were not adversely impacted as a direct result of
the COVID-19 pandemic and the ensuing economic challenges. As
part of the CARES Act, Congress amended the Fair Credit Report-
ing Act to ensure that consumers were protected during the pan-
demic, clarifying that accommodations made by lenders or other
creditors for customers were not included as negative entries on
their credit reports.
The credit bureaus themselves made additional accommodations
to serve customers during the pandemic, and I look forward to
hearing more about their activities during today’s hearing.
Despite many advancements and innovations in financial serv-
ices, a staggering number of Americans remain unable to access
credit. A recent study by the Federal Reserve Bank of New York
found that at the end of 2018, approximately 26.5 million adult
Americans, or roughly 10.5 percent of the population, were not in
the formal credit economy and, thus, did not have a credit history.
This so-called credit invisibility disproportionately impacts con-
sumers in rural areas and can perpetuate the cycle of reduced ac-
cess to traditional financial services. While many consumers may
not have traditional credit histories, they should be able to leverage
alternative examples of their financial health. On-time payment of
cell phone bills, rent, utility bills, and other payments, and other
alternative data are indicative of a consumer’s ability to repay.
I hope to learn more about how the credit bureaus are innovating
to account for this alternative data and the outlook for expanding
credit availability to underserved or credit-invisible individuals.
Unfortunately, some on the other side, including President
Biden, are using imperfections in the current credit reporting land-
scape to push for radical solutions that would increase prices for
consumers, limit competition, and make credit less available, espe-
cially for low- and moderate-income borrowers.
The Biden Administration has proposed eliminating the private-
sector credit bureaus and replacing them with a centralized, na-
tionalized credit reporting bureau run by the CFPB. While the cur-
rent credit reporting system is not perfect, nationalizing the proc-
ess and thus eliminating all incentives for sound customer service
and innovation will leave consumers further behind.
Appropriate government oversight of the credit reporting agen-
cies and private-sector innovation is the most effective means to re-
duce credit data errors and bring about a more inclusive credit sys-
tem.
We have also heard a growing chorus of my colleagues on the
other side calling to eliminate risk-based pricing in financial serv-
ices. The risk-based pricing in credit allocation insurance and other
financial products is essential to ensuring that consumers are pay-
ing the appropriate price for the products, firms are adequately
managing risk, and allocation of credit is not arbitrarily limited
based on onerous one-size-fits-all restrictions.
Firms are prohibited from pricing risk based on race, nationality,
religion, or other demographic characteristics, instead focusing on
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4
the metrics that demonstrably and accurately reflect a consumer’s
ability to repay.
A recent study from the U.S. Chamber of Commerce illustrates
that eliminating risk-based pricing and replacing it with a uniform
pricing model would raise prices on consumers and limit avail-
ability of credit and other financial services to low- and middle-in-
come borrowers. A prohibition on using predictive data would not
make the system more equitable, but instead dramatically exacer-
bate the inequalities we all hope to eliminate.
I look forward to discussing these important topics today. And,
Mr. Chairman, on a personal note, this will be my last hearing as
ranking member of the Oversight and Investigations Sub-
committee, as I move on next month to serve as the ranking mem-
ber of the National Security, International Development and Mone-
tary Policy Subcommittee. It has been a pleasure serving on this
subcommittee with you.
Thank you, and I yield back.
Chairman GREEN. The gentleman yields back. And the Chair
would like to, if I may, briefly state that I have enjoyed working
with you as well, and I am sure we will find additional opportuni-
ties to work together. Congratulations on your new station in life.
The Chair now recognizes the Chair of the full Financial Services
Committee, the gentlewoman from California, the Honorable Max-
ine Waters, for 1 minute. You may be on mute, Madam Chair-
woman. We may be having some technical difficulties.
While we examine our technology to ascertain whether we are
having such difficulties, please allow me now to recognize the Vice
Chair of the subcommittee, a person who has been a friend of mine
for a number of years, the gentlewoman from Georgia, Ms. Wil-
liams, for 1 minute.
Ms. WILLIAMS OF GEORGIA. Thank you, Mr. Chairman, and I am
honored to be serving in my first hearing today as Vice Chair of
the Oversight and Investigations Subcommittee.
On this subcommittee, we consistently uplift those most
marginalized, something that I strive for in all that I do in Con-
gress. We uncover the information needed to inform better policy
and ensure that government agencies and programs are indeed
working for the people.
I am grateful for the opportunity to help lead the important work
of the Financial Services Committee’s investigative arm, and today
we will take a deep dive into credit reporting. An individual’s credit
score can determine whether they can do things like buy a house,
start a small business or, more broadly, build a better life for them-
selves and their families.
To help hardworking folks get ahead in the wake of this pan-
demic, ensuring that credit reporting is fair, accurate, and con-
sumer-friendly will be of the utmost importance. I look forward to
hearing from our witnesses today, and working together with my
colleagues on this important issue.
Mr. Chairman, thank you, and I yield back.
Chairman GREEN. The gentlelady yields back. And the Chair ne-
glected to congratulate the gentlelady for her new station in life.
I commend you, and I do look forward to working with you as well.
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5
The Chair will now introduce the witnesses. I welcome our wit-
nesses, and I am pleased to have the opportunity to introduce
them: Ms. Chi Chi Wu, a staff attorney at the National Consumer
Law Center; Ms. Beverly Anderson, president of global consumer
solutions at Equifax; Ms. Sandy Anderson, senior vice president of
operations at Experian North America; Mr. John Danaher, execu-
tive vice president of consumer interactive at TransUnion; and Ms.
Rebecca Kuehn, a partner at Hudson Cook Law Firm, who is testi-
fying on behalf of the Consumer Data Industry Association.
The witnesses are reminded that your oral testimony will be lim-
ited to 5 minutes. You should be able to see a timer on your screen
that will indicate how much time you have left. A chime will go off
at the end of your time, and I would ask you to be mindful of the
timer and quickly wrap up your testimony if you hear the chime
so that we can be respectful of both the witnesses’ and the com-
mittee members’ time.
And without objection, your written statements will be made a
part of the record. Once the witnesses finish their testimony, each
Member will have 5 minutes to ask questions.
Before I go to Ms. Wu, I have been given an indication that
Chairwoman Waters is now available; hence, I will recognize the
Chair of the Full Committee for 1 minute, and then we will move
on to Ms. Wu. Chairwoman Waters, you are now recognized.
Chairwoman WATERS. Thank you very much, Mr. Green, for
holding this important hearing on credit reporting.
In February 2019, one of the first hearings I convened as chair-
woman was the hearing with the three CEOs of Equifax, Experian,
and TransUnion, the national credit bureaus, to examine the ways
in which the current system fails to protect consumers. We ad-
vanced several bills through the House to fix the broken credit re-
porting system, but unfortunately, the Senate failed to act.
Consumer credit reporting complaints to the CFPB more than
doubled from 2019 to 2020, suggesting a surge in more credit re-
porting errors during the pandemic. We must learn what is behind
these trends and what the credit bureaus must do to protect our
consumers.
I thank you very much, and I yield back the balance of my time.
Chairman GREEN. I now recognize Ms. Wu for 5 minutes to give
an oral presentation of her testimony.
STATEMENT OF CHI CHI WU, STAFF ATTORNEY, NATIONAL
CONSUMER LAW CENTER (NCLC)
Ms. WU. Thank you, Mr. Chairman. Mr. Chairman, Ranking
Member Barr, members of the subcommittee, and Chairwoman
Waters, thank you for inviting me to testify today. I am testifying
on behalf of the low-income clients of the National Consumer Law
Center.
I have been testifying on credit reporting abuses since 2007. Be-
fore me at NCLC was Tony Rodriguez. He went on to the CFPB,
and the Federal Trade Commiwion (FTC), and we just celebrated
his retirement yesterday. Before him was our former director, Will
Ogburn, in fact, the first director of NCLC, who testified in FCRA
hearings in 1969.
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I mention this because it shows that we have been balloting the
abuses of credit bureaus for a very long time, and yet it hasn’t got-
ten better. In fact, it might have gotten worse: 300,000 complaints
to the CFPB in 2020. That is a lot of complaints, twice as many
as last year, and nearly two-thirds of the complaints to the CFPB.
And, of course, according to the FTC’s 2012 study, there are 10 mil-
lion Americans who have errors so serious on their credit reports
that it could deny them credit or cost them more for credit.
And, no, this explosion in complaints isn’t just credit repair out-
fits challenging accurate information. The CFPB has said there is
no evidence of that. The credit bureaus have been blaming credit
repair for decades. It is the same-old, same-old.
What is different? A pandemic, of course, with devastating eco-
nomic impacts on many Americans, potentially causing more folks
to check their credit reports, which the credit bureaus commend-
ably did make available once per week for free; the CARES Act,
with its complicated provisions that some creditors seem to be trip-
ping up on; and a looming rental housing crisis with 8 million to
10 million Americans possibly facing eviction.
The last issue is another possible reason that complaints have
exploded: The fact that nowadays 90 percent of landlords conduct
credit checks as part of tenant screening pushed by the credit bu-
reau’s expansion into new uses and the thirst for more customers
and more sales.
An article from this past Sunday’s New York Times documents
how millions of Americans are being shut out of stable rental hous-
ing by credit checks. The article notes how a survey of residents
in extended hotels in Norcross, Georgia, 70 percent of whom were
Black, named credit as the biggest barrier for more permanent
housing, and 600 students stay at extended-stay hotels in the larg-
est school system in Georgia, 600 children without a permanent
roof over their heads, in part because of the credit bureaus.
Simply put, using credit scores in housing worsens the already
terrible economic and racial inequality in our country. And, of
course, being denied housing provides a great incentive to check
your credit report and dispute errors. The credit bureaus only have
themselves to blame. The more they hawk their products for inap-
propriate uses, the more that 10 million Americans with serious er-
rors are going to find those errors and complain.
Speaking of credit repair, the credit bureaus complain so much
about it, but according to a recent legal case, they have agreements
with Lexington Law, the second-biggest credit repair firm. If they
complain about it so much, why do they have agreements in it? By
the way, the CFPB sued Lexington Law for deceptive advertising.
If you don’t believe me that the explosion of complaints is not il-
legitimate credit repair, check out the narratives in the CFPB com-
plaint database and read for yourself. We have highlighted a few
in our written testimony. Here is an example.
‘‘In addition to TD Bank posting the account as paid in full, they
reported me as deceased. I wouldn’t have known this except I was
trying to get a mortgage and my bank told me that Experian and
Equifax showed me as deceased based on TD Bank’s report.’’
The consumer goes on to say, ‘‘I called X and X but also could
not prove to them to their satisfaction, despite answering all their
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7
questions as to my identity, that I am, in fact, alive. I was unable
to get the mortgage due to these errors on my credit report and the
inability or unwillingness of these companies to correct their er-
rors.’’
One reason why credit bureaus might actually not mind credit
repair is this huge volume of disputes. In fact, they actually don’t
do a heck of a lot when they get a dispute. They have automated
the heck out of the system to the point where when a consumer
disputes online, it automatically flows to the information furnisher,
with no need for work by the credit bureaus.
Even for paper disputes, the main job of offshore venders to han-
dle these disputes is to pick a two- or three-digit code to categorize
this dispute, maybe add a line of text, upload documents, and send
it to the furnisher. So for nonexistent or very little work on most
disputes, the automated system used for processing disputes called
e-OSCAR charges $0.30 per dispute.
As you can imagine, more disputes equals more fees. Always fol-
low the money. It is time for a public credit registry that will treat
Americans fairly, fix disputes, and not try to expand credit report-
ing to every conceivable aspect of American life, however inappro-
priate. I thank you for the opportunity to testify, and I look for-
ward to your questions.
[The prepared statement of Ms. Wu can be found on page 71 of
the appendix.]
Chairman GREEN. Thank you, Ms. Wu.
The Chair now recognizes Ms. Beverly Anderson for 5 minutes
to give an oral presentation of her testimony.
STATEMENT OF BEVERLY ANDERSON, PRESIDENT, GLOBAL
CONSUMER SOLUTIONS, EQUIFAX INC.
Ms. BEVERLY ANDERSON. Chairman Green, Ranking Member
Barr, members of the subcommittee, and Chairwoman Waters,
thank you for the opportunity to testify today. I am Beverly Ander-
son, president of global consumer solutions, and I am responsible
for providing free and paid credit and identity products, services,
and education to consumers.
I want to recognize that credit reporting accuracy is a common
priority that Equifax shares with consumers, lawmakers, regu-
lators, and financial institutions. Under the Fair Credit Reporting
Act, consumer reporting agencies and data furnishers must meet
stringent requirements for accuracy, fairness, and privacy.
I have a personal passion to support financial inclusion and a
professional responsibility to assist consumers as they consider the
most significant financial decisions. I understand how frustrating
it can be for a consumer to be on the cusp of an exciting financial
event only to discover an issue with their credit report. When I
hear these stories, it strengthens my resolve to do better.
The increase in complaints against Equifax through the CFPB
consumer complaint database is concerning. I interpret the in-
crease not as an indictment that the credit bureau’s system is bro-
ken, but rather as evidence that the national credit bureaus play
an important role in facilitating the dispute process between con-
sumers and their creditors.
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8
Let me briefly review three factors to contextualize the increase
in complaint volume. First, consumers submitted more complaints
against the national credit bureaus through the CFPB portal as the
CARES Act protections appeared on their credit reports. The
COVID pandemic presented an extraordinary set of challenges for
American consumers.
Congress moved quickly in early 2020 to pass the CARES Act,
which included new consumer protections such as mortgage for-
bearance, an eviction moratorium, and a pause on student loan
payments. As a result, lenders took swift action to comply with the
new CARES Act provisions and data reporting requirements. With
the combination of consumer economic uncertainty and the imple-
mentation of new accommodations, consumers reviewed their credit
reports more often.
Second, consumers routinely submit complaints to the CFPB that
are not complaints about credit bureau actions but rather disputes
about data reported to us. Consumer reporting agencies serve as an
intermediary between consumers and their lenders.
Our data show that 95 percent of portal complaints involve dis-
putes that typically relate to information provided by a lender, an
outdated address, or a credit score. Therefore, most complaints
against the national credit bureaus in the CFPB portal should not
be attributed to errors made by the credit bureaus.
And, third, the portal has been inundated by submissions from
credit repair organizations disputing adverse but accurate informa-
tion on consumer reports. Recent internal Equifax reviews indicate
that 65 percent of complaints in the portal appeared to be associ-
ated with credit repair organizations.
Let me close my opening remarks by reviewing Equifax’s efforts
to assist consumers through the pandemic. In April 2020, and at
my direction, we quickly launched a COVID and credit financial re-
source vendor to help consumers understand and evaluate the im-
pact of the pandemic on their finances. I personally conducted pub-
lic webinars and recorded podcasts to assist consumers.
As the pandemic took hold, the three national credit bureaus col-
lectively decided to provide consumers with free credit reports each
week. And in March of this year, we extended that initiative
through April of 2022. Equifax continues to invest millions of dol-
lars to deliver exceptional care to consumers in our quest to become
the most consumer-friendly credit reporting agency (CRA).
We modernized our telephone and back-office infrastructure. We
have automated core processes, expanded call center hours, and
upscaled our agents. My goal is for Equifax to be accessible, re-
sponsive, caring, and efficient at every touch point in a consumer’s
engagement. I am proud of the work that Equifax has done to as-
sist consumers through the pandemic, and I pledge to do more.
I look forward to answering your questions. Thank you.
[The prepared statement of Ms. Beverly Anderson can be found
on page 36 of the appendix.]
Chairman GREEN. Thank you, Ms. Anderson.
Ms. Sandy Anderson, you are now recognized for 5 minutes to
give an oral presentation of your testimony.
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9
STATEMENT OF SANDY ANDERSON, SENIOR VICE PRESIDENT,
OPERATIONS, EXPERIAN NORTH AMERICA
Ms. SANDY ANDERSON. Thank you, Chairman Green, Ranking
Member Barr, Chairwoman Waters, and members of the sub-
committee. I am Sandy Anderson, senior vice president of oper-
ations for Experian North America.
Let me begin by stating why credit bureaus exist and how con-
sumers benefit. Credit bureaus accurately compile individual’s pay-
ment histories reported to us by creditors so that lenders can use
this data to make sound underwriting decisions. Sound lending de-
cisions for credit cards, autos, and mortgages mean fewer defaults.
Fewer defaults mean lower cost of credit for consumers and greater
availability of consumer credit across the economy.
Credit bureau data is blind to factors such as race, ethnicity, and
gender, so it helps lenders ensure compliance with the Equal Cred-
it Opportunity Act (ECOA). What we hear most often from con-
sumers and policymakers is that they want us to focus on three
clear objectives: ensure the information we hold on consumers is
secure; make credit reports accurate; and manage a data dispute
system that is easy for consumers to access and use.
Experian wholly understands these responsibilities and has sig-
nificantly shifted its focus to the consumer. Experian has kept pace
serving consumers during the COVID-19 pandemic and will con-
tinue as our nation’s economy recovers. We have responded com-
pletely and accurately to all consumer complaints to the CFPB
complaint portal. We believe most of the increase is due to third-
party credit repair shops that file disputes on accurate but negative
information to try and game the system.
The number-one priority at Experian is keeping consumer infor-
mation safe and secure, and we are working on our own initiatives
and with our regulators under continuous supervision on this pri-
ority.
Experian supports this committee’s goal of enhancing the accu-
racy of credit reports and improving the dispute resolution process.
We believe the best way to achieve and maintain improvements on
behalf of consumers is through a robust and continuous supervision
and examination program, which has been administered by the
Consumer Financial Protection Bureau since 2013. We have imple-
mented many new initiatives as a result.
Experian has invested heavily in systems and processes to im-
prove data accuracy as we continually strive to reach 100-percent
accuracy. Stringent requirements are in place to identify and elimi-
nate inaccurate data submitted monthly by approximately 10,000
data furnishers before it is included in a consumer’s file. Experian
provides data furnishers with monthly reports describing any of
their data we have rejected and why and providing them with his-
torical information about their data contributions and consumer
dispute performance.
Through this transparent feedback loop, Experian is making con-
tinuous progress in eliminating errors even before data is sub-
mitted to us. An important component of accuracy is to make credit
reports accessible for consumers so that they can easily review and
dispute errors in their file. Experian’s online dispute portal, includ-
ing a mobile, optimized, and highly-rated app, makes it easy for
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10
consumers to submit disputes and to receive the results of those
disputes.
Experian also supports the committee’s goal of creating more op-
portunities for financial inclusion and financial literacy for con-
sumers who are thought of as credit invisible. Many consumers
may not have a mortgage or credit cards, but they do make tele-
phone, utility, and other recurring monthly payments. Experian is
now accommodating this data through a groundbreaking product
known as Experian Boost. We are delivering this data directly to
lenders so that they can expand their efforts to reach underserved
consumers.
Experian Boost is a game changer. It allows consumers to safely
and easily opt in to having monthly payment information on ac-
counts that are not reported to the CRAs included directly into
their credit file. Experian Boost is particularly helpful to con-
sumers who are new to credit or have had financial challenges. So
far, more than 6 million consumers have chosen to use Experian
Boost to improve their credit score.
To help improve financial literacy, Experian is also providing ac-
cess to free credit monitoring, free credit reports, free credit scores,
and financial education to more than 40 million U.S. consumers.
Experian is also partnering with lenders through the OCC’s Project
REACh initiative to identify new sources of predictive data that
can be used to improve access to credit for underserved and
marginalized consumers.
Thank you for inviting me to testify, and I look forward to an-
swering your questions.
[The prepared statement of Ms. Sandy Anderson can be found on
page 43 of the appendix.]
Chairman GREEN. Thank you, Ms. Anderson.
Mr. Danaher, you are now recognized for 5 minutes to give an
oral presentation of your testimony.
STATEMENT OF JOHN DANAHER, EXECUTIVE VICE
PRESIDENT, CONSUMER INTERACTIVE, TRANSUNION
Mr. DANAHER. Chairman Green, Ranking Member Barr, Chair-
woman Waters, and members of the subcommittee, thank you for
the opportunity to participate in this afternoon’s discussion of these
critical policy issues. My name is John Danaher, and I serve as ex-
ecutive vice president of TransUnion’s consumer interactive busi-
ness.
TransUnion is a global information and insights company
headquartered in Chicago with more than 4,000 employees in the
United States and 8,200 worldwide. We seek to help people around
the world, through the power of information, to identify and access
opportunities that bring a higher quality of life.
Our consumer interactive segment helps consumers manage their
personal finances and take precautions against identity theft. We
provide consumers with credit scores, credit reports, credit moni-
toring, fraud prevention and support, and financial management
tools. We also provide credit monitoring solutions that help busi-
nesses respond to data breach events.
Our direct to consumer products help Americans achieve finan-
cial freedom and elevate their lives. The past 14 months were un-
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11
like any in our history, and we believe all of us must work together
to protect and support consumers. TransUnion recognizes our cen-
tral role in ensuring the fairness and stability of our nation’s con-
sumer credit markets, and we are eager to partner with this com-
mittee to help all consumers, especially the most disadvantaged
Americans and those affected by the pandemic.
The pandemic required novel and significant consumer support
efforts both from the private sector and the Federal Government.
At TransUnion, we immediately pivoted our workforce to remote
servicing while still providing consumers the necessary support
they needed to navigate the pandemic.
Our data indicates that both lending and the broader economy
are normalizing, but serious challenges continue to persist for
many consumers. Helping consumers affected by the pandemic se-
cure the financial protection they need has been and continues to
be one of our top priorities. We are regularly communicating with
lenders, property management firms, scoring companies, and data
furnishers on how they can provide relief to customers through es-
tablished hardship programs.
It is incumbent on our industry to support the policy objectives
of the bipartisan CARES Act, and we are pleased that the accom-
modations provisions at the core of that law are working. We esti-
mate more than 200 million consumer accounts have been placed
in protective accommodations because of the CARES Act.
At the onset of the pandemic, TransUnion led the effort to ex-
pand the availability of free credit reports to all consumers on a
weekly basis. We are proud to report that more than 166 million
consumers have used our services to access their credit data. It is
undeniable that the pandemic is exacerbating preexisting struc-
tural inequalities with underrepresented Americans facing unique
challenges.
We are striving to address matters of racial equity and want to
be at the vanguard of defining consumer-focused principles for the
next generation of data use. To that end, last year we launched
TransUnion’s Task Force on Racial Equity, which I lead. As part
of this work, we are ensuring that all uses of TransUnion’s prod-
ucts and solutions are consistent with our values and the goal of
financial inclusion in the economies we serve.
We are also redoubling our efforts in supporting the proliferation
of alternative data, which is the most direct way to expand credit
to historically disadvantaged groups. Notably, we are working with
the OCC on its Project REACh efforts. TransUnion believes alter-
native data is a racial justice issue. Millions of underrepresented
consumers make rental, utility, and other payments every month,
yet the current system gives them no credit, often rendering them
credit invisible.
TransUnion is committed to helping Americans protect their fi-
nancial health during and after the pandemic. We look forward to
working with Congress to foster financial inclusion and further em-
power consumers. I appreciate the opportunity to be with you
today, and I look forward to answering your questions.
[The prepared statement of Mr. Danaher can be found on page
48 of the appendix.]
Chairman GREEN. Thank you, Mr. Danaher.
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Ms. Kuehn, you are now recognized for 5 minutes to give an oral
presentation of your testimony.
STATEMENT OF REBECCA E. KUEHN, PARTNER, HUDSON
COOK, LLP, ON BEHALF OF THE CONSUMER DATA INDUSTRY
ASSOCIATION (CDIA)
Ms. KUEHN. Chairman Green, Ranking Member Barr, Chair-
woman Waters, and members of the subcommittee, thank you for
the opportunity to appear before you today to talk about the con-
sumer reporting industry’s commitment to the accuracy of credit
reports. My name is Rebecca Kuehn, and I am a partner at Hudson
Cook, where I chair the Credit Reporting, Privacy, and Data Secu-
rity Practice Group.
I am appearing today on behalf of the Consumer Data Industry
Association, or CDIA. CDIA represents the nationwide credit bu-
reaus, regional and specialized credit bureaus, background check
and residential screening companies, and others. The credit report-
ing agencies here today and the CDIA members help the American
consumer and the larger economy by maintaining a robust con-
sumer reporting system that facilitates credit, employment, and
housing transactions nationwide.
CDIA members are helping to solve the problem of the unbanked
and credit-invisible populations through innovation by expanding
the kinds of data collected, such as rental history or payments on
telephone or other utility bills. This expansion gives lenders and
others information that allows more consumers to access tradi-
tional financial services and to integrate more consumers into the
mainstream financial system.
The principle law that governs the consumer reporting system is
the Fair Credit Reporting Act (FCRA). The FCRA requires con-
sumer reporting agencies to follow reasonable procedures to ensure
maximum possible accuracy of the information in consumer re-
ports. The maximum possible accuracy standard is not one of per-
fection, but it balances the protection of consumers and the needs
of commerce.
The FCRA recognizes that accuracy begins with the data coming
into the system. The lenders who provide that data, the furnishers,
must have reasonable policies and procedures to ensure the accu-
racy and integrity of the information they provide to consumer re-
porting agencies. The FCRA also gives consumers the right to dis-
pute the accuracy of information directly with those furnishers.
To ensure accuracy, the consumer reporting agencies screen lend-
ers before they even onboard them as furnishers, and furnished
data undergoes a number of checks and quality control measures
before it is added to a credit file. The nationwide consumer report-
ing agencies obtain information electronically using a standardized
reporting format to facilitate the accurate and consistent reporting
of data throughout the system.
The FCRA also provides consumers with the right to access infor-
mation about them and to dispute any inaccuracies. This dispute
process is an important and necessary component of ensuring accu-
racy. For this reason, the nationwide consumer reporting agencies
have made significant investments in consumer dispute resolution
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to make it easier for consumers to identify and correct potential er-
rors in their files.
These improvements, which are outlined in my written testi-
mony, include an escalation process for addressing disputes related
to mixed consumer files and identity theft. It also is important to
recognize that there is a market incentive to ensure maximum pos-
sible accuracy. The customers of the credit bureaus, financial insti-
tutions, and their regulators rely on and demand accurate data to
make critical decisions about credit. That demand drives accuracy.
In my written testimony, I address the number of credit report-
ing complaints to the CFPB and why those are not a good measure
of accuracy, particularly given the impact of bad actors, credit re-
pair operators on the numbers of complaints. I will be happy to ad-
dress any questions the subcommittee has.
But with my remaining time, I want to turn to the protections
that Congress enacted in response to the COVID-19 pandemic. The
CARES Act, passed in March 2020, implemented a number of sig-
nificant protections for consumers, including special credit report-
ing changes and payment deferrals. These changes allowed con-
sumers to preserve their credit history while they work through the
challenges of the pandemic, and the data shows that the impact of
these protections has been significant. The number of missed pay-
ments has gone down, and the national average FICO score went
up during 2020.
The three nationwide consumer reporting agencies have re-
sources on their websites to inform consumers of their options and
protections under the CARES Act, along with other resources that
are available to help them manage their credit during the pan-
demic. In addition, the nationwide consumer reporting agencies
have voluntarily increased the number of free reports available to
a consumer from once per year to once per week through April 20,
2022.
As we emerge from the pandemic, CDIA and its members are
committed to providing consumers with the tools they need to man-
age their financial future. I thank you for the opportunity to testify
before you today, and I will be happy to answer any questions.
[The prepared statement of Ms. Kuehn can be found on page 53
of the appendix.]
Chairman GREEN. Thank you, Ms. Kuehn.
The Chair will now recognize Members for 5 minutes for ques-
tions. I now recognize the Chair of the Full Committee, the gentle-
woman from California, Chairwoman Waters, for 5 minutes.
Chairwoman WATERS. Thank you very much, Congressman
Green.
I am going to address this question to Ms. Beverly Anderson.
Following enactment of the CARES Act, you said, ‘‘It will take a
moment to figure out how to execute against what has been stipu-
lated by the CARES Act, so something is bound to slip through the
cracks.’’
Earlier this year, the Subcommittee on Consumer Protection and
Financial Institutions held a hearing called, ‘‘Slipping Through the
Cracks’’, which provided a number of legislative solutions to help
America’s consumers in the pandemic. We cannot accept that con-
sumers will simply slip through the cracks.
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Let me give you one example we heard at the subcommittee
hearing. Carla Sanchez-Adams, managing attorney for Texas
RioGrande Legal Aid, said, ‘‘Many of our clients who have been
treated for the virus have expressed concern over medical debt col-
lection and insurance coverage. Ms. M. had a medical debt account
appear on her credit report for treatment her grandson received.
She was also contacted by debt collectors regarding the same med-
ical debt.
‘‘Ms. M.’s grandson was covered by Medicaid, and under Texas
law, neither Ms. M. nor her grandson were responsible for the costs
of any medical services provided to them. However, the debt collec-
tors continued to collect on the debt and report the debt.’’
So, this grandmother’s credit was harmed through no fault of her
own while her grandson was getting medical treatment for which
he was covered. It should not be complicated, and consumers
should not have to get a lawyer every time someone makes a mis-
take that shows up on their credit report, making it expensive for
them to get a loan, among other harms.
Yes or no, is Ms. M.’s case what you mean by saying, ‘‘something
is bound to slip through the cracks?’’
Ms. BEVERLY ANDERSON. Thank you, Madam Chairwoman, for
your question. I appreciate the fact that you have listened to one
of my podcasts or a webinar. And what I was simply stating—and
remember, this was in the early days of the pandemic, and con-
sumers were literally asking us questions about the various stipu-
lations and protections in the CARES Act. They wanted to know
how the CARES Act would protect them, what things might
change, what things would be different on their credit report, and
we were simply articulating that there might be things that are
confusing.
Chairwoman WATERS. Okay. Thank you very much. Reclaiming
my time, what have you done to ensure that people are not simply
falling through the cracks? What have you done to rectify that, to
lessen the number of mistakes that you make? Because this is
what is harming our consumers, the mistakes, and you can’t cor-
rect them once you do it, and we don’t get a lot of help from the
credit bureaus. What have you done?
Ms. BEVERLY ANDERSON. Data accuracy is an important part of
our mission—
Chairwoman WATERS. Yes, we know that, but what have you
done?
Ms. BEVERLY ANDERSON. —as it is with data furnishers. And so,
since 2012, we have been actively involved in addressing issues of
accuracy in terms of the way in which we work with furnishers. We
have an entire team who spends time vetting furnishers, vetting
the data that they provide us, and creating remediation plans,
quality controls and monitoring. And if a furnisher, in fact, fails to
meet our standards of data quality, we will prevent them from re-
porting—
Chairwoman WATERS. Reclaiming my time, how effective have
you been? And how much reduction have you had in these kinds
of, ‘‘falling through the cracks’’ instances?
Ms. BEVERLY ANDERSON. We know that we have made consider-
able progress, and we know that there is going—
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Chairwoman WATERS. How do you know that?
Ms. BEVERLY ANDERSON. We monitor all of the data that we re-
ceive, and we make sure that we are checking accuracy at every
turn.
Chairwoman WATERS. Give me some numbers. What is different
now than before?
Ms. BEVERLY ANDERSON. We know that we have created an op-
portunity for consumers to have—
Chairwoman WATERS. How do you know?
Ms. BEVERLY ANDERSON. Because of the data—
Chairwoman WATERS. We don’t have much time, and that is why
I have to take back my time. But I want to know how you are able
to define that you have been effective?
Ms. BEVERLY ANDERSON. We look at metrics in a number of
ways, and I would be happy to bring some of those metrics back
and share them with you.
Chairwoman WATERS. Thank you very much.
Mr. Chairman, I am going to ask that Ms. Anderson send us
back some information and some reports which show that they
have reduced or eliminated the number of mistakes that cause peo-
ple to fall through the cracks.
I yield back the balance of my time.
Chairman GREEN. The gentlelady yields back.
And without objection, the question will be submitted to Ms. An-
derson for her reply.
At this time, the Chair recognizes the ranking member of the
subcommittee, Mr. Barr, for 5 minutes.
Mr. BARR. Thank you, Mr. Chairman.
My first question is about risk-based pricing. Lenders, insurers,
and other financial market participants rely on risk-based pricing
for their products and services. They use data indicative of a con-
sumer’s ability to repay blind of race, nationality, religion, or other
amenable characteristics to give consumers the best price.
Ms. Kuehn, would you discuss the importance of risk-based pric-
ing in financial services; and, specifically, what impact would a
government-imposed prohibition on risk-based pricing or a man-
date for use of uniform pricing have on the price, availability, and
access to financial services?
Ms. KUEHN. Thank you, Representative, for your question. The
studies that have come out that are focused on risk-based pricing
have shown that if we abandon risk-based pricing, the result would
be an overall increase in the price of credit and a lessening of the
availability of credit for consumers. Risk-based pricing has enabled
more consumers to qualify for credit, even if traditionally, they
would have been declined. If we reverse this course, there will be
fewer consumers who qualify for credit.
Mr. BARR. Thank you for that. And I do worry about proposals
that would politicize the assignment of credit scores based not on
accurate data but on other factors that could be politically moti-
vated. That would, as you point out, increase the cost of credit for
everyone.
Let me talk about President Biden’s proposal for a Federal credit
bureau. As you all know, and has been pointed out today, President
Biden proposed eliminating private credit reporting agencies and
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replacing them with a public government credit bureau within the
CFPB. I believe this is an unnecessary Federal takeover of a pri-
vate industry at the expense of taxpayers.
Ms. Kuehn, what are some of the issues that you foresee with a
single, government-run credit bureau, and please amplify your tes-
timony about what I thought was a point well taken about the
market incentive that exists currently to maintain and improve the
accuracy and completeness of credit reports?
Ms. KUEHN. Thank you, Representative. From my background at
the FTC, I am very pro-competition, and the current market now
has three large credit reporting bureaus who compete with each
other for accuracy and on other products and services and innova-
tions. We believe that a government-run credit bureau would not
have those same incentives to find new solutions for consumers or
expand access.
The proposal today for the government-run credit bureau would
leverage the same data that is here already in the system. Our
members are looking for new and different sources of data, and
that type of innovation fuels additional entrants into the credit
market.
In addition, we take issue with this concept that the government-
run credit bureau would be more answerable to consumers. Under
the current system, consumers have not only the right to dispute,
but they also have significant private causes of action that enable
them, if all else fails, to bring private lawsuits against the credit
bureaus and obtain money in court. It is unclear whether the gov-
ernment-run credit bureau would be similarly answerable to con-
sumers when problems occur and with large sets of data, sir.
Mr. BARR. Ms. Kuehn, that is a good point about being respon-
sive to consumers, but I am also worried about the politicization
that could happen with a single government bureau. We have seen
that with the CFPB itself. And so, the accuracy of information
based on just data and not other extraneous factors, I think, is
really, really important.
Finally, alternative data, and I will ask Ms. Kuehn, but any of
the representatives of the CRAs can chime in because of the inno-
vations that are happening in terms of alternative data. I think
Experian Boost is an example of this. Mr. Danaher, you had an in-
teresting piece of testimony about what is the—let’s see, I high-
lighted it—the CreditVision Suite. I thought that was very inter-
esting and innovative. How would utilization of this data by credit
reporting agencies help Americans gain access to credit?
Ms. KUEHN. What we have seen so far—go ahead.
Mr. BARR. Go ahead.
Ms. KUEHN. Sorry. What we have seen so far, Representative, is
that it reaches more consumers. For those who don’t have a tradi-
tional credit history, these alternative data sources act as good his-
tory they can build on to further their credit goals. And so, for folks
like new entrants to the credit market, be it younger Americans or
immigrants, we are able to leverage this information that they al-
ready have and turn it into credit information. Thank you.
Mr. BARR. My time has expired, but I love this private sector in-
novation on financial and credit inclusion that I doubt a govern-
ment agency would ever be able to do.
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I yield back.
Chairman GREEN. The gentleman’s time has expired.
The Chair now recognizes Ms. Tlaib, the gentlelady from Michi-
gan, for 5 minutes.
Ms. TLAIB. Thank you so much, Mr. Chairman. I really do appre-
ciate this incredibly important hearing, especially because so many
of our families are directly impacted by the way credit reporting is
conducted now.
I do have some questions for everyone on the panel, and I think
this is so important because the initial intent for credit reporting
was for lending, and now it is impacting access to transportation.
It is also the leading cause for many of our veterans, who really
come back from serving our country with no access to credit be-
cause they weren’t here to spend or to apply for credit cards or
whatever the processes that these private agencies decide related
to what a credit score is.
My question to those on the panel is, what does a credit score
have to do with someone’s driving record, whether or not they are
a good driver? Does anybody know the answer to that question?
Ms. WU. Thank you for the question, Congresswoman Tlaib. It is
an excellent question. And I would say, absolutely nothing. A credit
score should be used for one thing only and that is credit. It doesn’t
have—
Ms. TLAIB. That is correct.
Ms. WU. —anything to do with your driving, with your ability to
do a job as a worker, with your honesty. It has nothing to do with
your character. It predicts whether there is going to be a 60-day
late payment in the next 2 years, and it shouldn’t be used for hous-
ing and is shutting out so many low-income Americans from per-
manent housing, as the New York Times documented in a very
heartbreaking manner.
Ms. TLAIB. Yes. Ms. Wu—
Ms. WU. Credit scores should only—
Ms. TLAIB. Yes. And, Ms. Wu, you should know—and many of
the folks, I would love to hear their answers, too—the University
of Michigan did a wonderful study showing that it actually kept
people in the cycle of poverty, that the fact that credit scores are
now being used for auto insurance, which is happening right now
in my district, we have the highest in the nation, over $5,000 aver-
age per household.
And so for many of my frontline workers, many of my teachers,
some of whom have second jobs just to pay for auto insurance be-
cause, again, the use of the credit score is a heavy weight on the
calculation of the rates of auto insurance. Does anybody else know
what the credit score has to do with somebody’s driving record?
Why is that being considered? Why are you all reporting credit
scores to auto insurance industries other than making money?
Ms. KUEHN. Thank you, Representative, for your question. The
FTC actually did a study on credit-based insurance scores following
the Fair and Accurate Credit Transactions (FACT) Act in 2003, and
in its look at the use of credit in insurance determinations found
that there was a correlation between the way someone pays their
bills and whether or not they are going to cost more as an insur-
ance recipient.
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Ms. TLAIB. So if they are low income and they have a hard time
paying their bills, then let’s raise their rates on auto insurance. It
has nothing to do with whether or not they are a good driver; it
is, let’s punish them because they are poor, because they can’t af-
ford to pay their auto insurance. That is what I am hearing when
I hear about these studies.
But I am really wondering whether or not you all would support
a study of the disparate impact of using credit scores as a factor
for auto insurance rates? Would anybody be opposed to that?
Would you want to know if structural racism exists in the use of
credit scoring for auto insurance? Would you want to know that as
a business in the United States?
Ms. KUEHN. Representative, the FTC study that focused on cred-
it-based insurance scores looked at that as part of its assessment,
and similar to the Federal Reserve study, found that the factors
that go into credit scores are neutral and therefore—
Ms. TLAIB. Interesting.
Ms. KUEHN. —in the appropriate risk rank—
Chairman GREEN. Even though it has resulted in more Black
folks getting higher rates of auto insurance than their White coun-
terpart neighbors?
Ms. KUEHN. That is—
Ms. TLAIB. So, disparate impact, Ms. Kuehn, do you see what I
am saying here? The result—you can say it is neutral, but the ap-
plication in itself—and Chairman Green knows that I have been
pushing for this study. He knows that this is really critically im-
portant to understanding, when we say disparate impact, what we
mean is the—it is not direct intentional discrimination. But by
using the credit score for that, it is, in essence, keeping people in
poverty, and that tends to impact communities of color specifically.
And it is just ridiculous that someone who is a doctor—this is the
honest truth—and somebody with a DUI, a driving under the influ-
ence violation, is paying less insurance than somebody with a bad
credit score, not the greatest credit score, even though they don’t
have a DUI on their record.
Do you see the absurdity of it all? Do you understand that my
folks who are low income, the ones who are cleaning your hotel
rooms, the ones who are putting food on your table at the res-
taurants, these folks who can’t afford to pay some of the high cost
of living in the United States, they can’t even pay their water bills,
you are telling me, let’s punish them, because they can’t afford
high rates of auto insurance? Let’s go ahead and sell credit reports
to auto insurance industries.
It has nothing to do whether or not they are going to be a safe
driver, it has nothing to do whether or not their car is a safe car,
it has nothing to do with the length of time it takes them to go
from their home to their job. It is absurd that you all stand with
that when we all know it is because you get the new customers.
You get customers, meaning they buy your credit reports from you
and you make money off of keeping people in poverty.
Do you see what I am saying? So, it is really hard for me to con-
tinue to hear this kind of rhetoric and the excuses that come out
of these credit reporting agencies. Shame on you. Shame on all of
you for keeping people in poverty in our country. Shame on you for
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19
targeting Black and Brown communities, because I see it. That is
exactly what you do.
And when I see, Mr. Chairman—the last point is so important.
When I see the number-one issue, the number-0one reason that we
see bankruptcy, personal bankruptcy in our country is medical
debt.
So, I hope the credit reporting agencies support our bill that
passed out of the Financial Services Committee, that bars medi-
cally necessary debt, procedures that are needed and required—
this is H.R. 2537, the Consumer Protection for Medical Debt Collec-
tions Act, which requires them not to put medically necessary debt
on your credit report because it—listen, they needed it to live. It
is not their fault that they got sick.
And just because they are poor, they shouldn’t be pushed back
and not allowed to get these procedures done. In this country, you
shouldn’t have to die because you are poor. Do you understand? So,
it is so important, Mr. Chairman, that we continue to have hear-
ings like this to expose the truth.
I appreciate it, and I yield back.
Chairman GREEN. The gentlelady yields back.
Mr. BARR. Mr. Chairman, point of order.
Mr. Chairman, can we have—
Chairman GREEN. Excuse me, please. Let the Chair recognize
you first, if you would, please.
Whom should I recognize?
Mr. BARR. This is Mr. Barr.
Chairman GREEN. Mr. Barr, you are now recognized for your
point of order.
Mr. BARR. Thank you. I just wanted to make sure we are check-
ing the accuracy of the clock. Could you check with the clerk? I
think we have had some inadvertent pauses on the time—the
countdown on the clock. Could you just check on that, Mr. Chair-
man?
Chairman GREEN. I will keep an eye on it. Thank you very much
for calling it to my attention.
And with that said, the Chair will now recognize the gentleman
from Georgia, Mr. Loudermilk, for 5 minutes.
Mr. LOUDERMILK. Thank you, Mr. Chairman. I appreciate the op-
portunity to be a participant in this hearing. It is very important,
and one of the complaints that we sometimes hear about the credit
bureau is, there is not enough competition. I, and I know many of
my colleagues, support competition in this industry and have sup-
ported legislation and conducted oversight of the FHA to bring
more competition to the credit reporting and scoring, but the Biden
Administration has proposed eliminating competition by creating
another government entity, a government credit bureau.
Ms. Anderson of Experian, what would the consequences be if
Congress replaced the current system with a government-run credit
bureau.
Ms. SANDY ANDERSON. Yes. Thank you for that question, Con-
gressman. We believe at Experian that the system is working: it
does drive competition; it does drive innovation; it allows us to
bring to market solutions like Experian Boost to bring in data that
is not part of the existing credit reports; and it allows consumers
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20
to expand that information in their credit report and allows lenders
to use that in order to serve underserved and financially challenged
consumers.
So, we believe that this system works with the appropriate level
of oversight by the CFPB and that competition drives innovation.
Mr. LOUDERMILK. I appreciate that. And using the tools that we
need, it is all about mitigating risk. It is about, lenders want to
lend money. That is how they make their profit. Auto dealers, they
want to sell cars. That is how they make a living, but the only way
that they can do this and do it affordably, in other words, making
loans at an interest rate commensurate with the risk, is if they
know what the risk is.
And in some cases, people will be denied credit or they will be
charged more for credit simply based on the risk. And so, my fear
is that a government bureau is not going to be looking just at the
data, but at an expected outcome, and that is when we get in trou-
ble.
A recent study from the U.S. Chamber of Commerce indicates
that risk-based pricing in lending is good for consumers and that
credit scores predict risk without bias. The other Ms. Anderson of
Equifax, can you discuss why it is so important to have robust
credit scores in the credit-based economy and why is it counter-
productive to suppress negative information on your credit reports?
Ms. BEVERLY ANDERSON. Thank you, Congressman. I absolutely
believe that it is necessary and important to have credit scores in
the economy. It is important for us to understand by using access
to data and providing that data to lenders so that they can, in fact,
make fully informed decisions on extending credit to consumers
and extending credit to consumers at reasonable rates based upon
the risk.
I also think it benefits consumers. Consumers have the oppor-
tunity to get access to credit and to also get access to credit at af-
fordable rates. The access of credit scores in the system allowed for
consumers to get credit, particularly quick, consistent access to
credit that you don’t see in many countries. Today, a consumer can
walk onto an auto lot and buy a car, because of the ability for a
lender to have full information, and make a ‘‘yes’’ credit decision.
So, it is important for us to have a fully functioning credit system
with full information.
Mr. LOUDERMILK. So, you would say that a good credit rating
system that mitigates risk is good for the consumers, because it
helps effectively lower the rates for consumers to increase their
buying power? If we didn’t have this way of determining who is of
greater risk, would you say that the result would be that most, if
not all consumers would then pay a higher rate because they have
to make up for the bad debt that would be out there that would
be issued by those who didn’t pay? Does that make sense?
Ms. BEVERLY ANDERSON. Yes, I agree.
Mr. LOUDERMILK. Okay. Mr. Danaher, as you know, the alter-
native data provides major benefits to consumers who previously
had little or no credit history. Should Congress pass legislation to
expand the types of data included in credit reports?
Mr. DANAHER. Thank you, Congressman. Yes, we fully support
the reporting of alternative data as we are characterizing it, rental
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payments, utility payments, telcopayments, because we believe that
greatly expands access to credit.
Our analysis shows that maybe up to 60 million Americans who
are currently invisible or slightly invisible to the system would be-
come visible. And as you pointed out, lenders want to lend and
lenders will figure out how to lend to those folks once they are visi-
ble to the system.
So, we fully support any efforts for the provision of alternative
data to us to expand access to consumers.
Mr. LOUDERMILK. Following up with that, are there some im-
provements that can be made to the system such as updating credit
files promptly instead of the consumer having to wait 30 days for
changes to be reflected on their credit report? Do you agree that
is a needed reform, and can you elaborate on that?
Mr. DANAHER. Yes, I do. The FCRA and those standards were set
years ago, before the great advances in technology, and we do have
the ability now to take in data faster and that benefits consumers.
Mr. LOUDERMILK. Okay. Thank you.
I yield back.
Chairman GREEN. The gentleman’s time has expired.
And with reference to the ranking member’s comment, I do agree
that we are having some problems with our timer. In fact, this time
we extended more than 6 minutes to the member, but I will try as
best as I can to keep an eye on it, and staff is working on the prob-
lem.
With this said, Ms. Adams, the gentlelady from North Carolina,
will be recognized for 5 minutes for her questions.
Ms. ADAMS. Thank you, Mr. Chairman, for convening this hear-
ing today. And to our witnesses, thank you for joining us as well.
The role that our credit bureaus play as consumer credit report
databases is critical both to lenders, but especially to borrowers. A
borrower’s credit report could mean the difference in getting afford-
able capital or being forced into a more expensive product or not
receiving credit at all. It has been more than 15 years since Con-
gress has enacted comprehensive reform of the consumer reporting
system and it is widely accepted that the current system has nu-
merous shortcomings that need to be addressed.
And that is why I am planning to reintroduce my bill, the Im-
proving Credit Reporting for All Consumers Act, that would im-
prove the dispute process for consumers, place better requirements
on furnishers to retain records on consumers, and provide con-
sumers greater transparency regarding the documents used to de-
termine the accuracy and completeness of disputed items.
We must do all that we can to ensure that consumers are fully
knowledgeable about their options and have the necessary re-
sources available to them to ensure that their financial health and
well-being is secure.
Ms. Anderson, and Mr. Danaher, I believe that you all would
agree that maintaining accuracy, completeness, transparency, and
access at the bureaus is very important. Since the FTC study of
credit reporting accuracy was nearly a decade ago, there has been
no broad-based public analysis of the accuracy of and the error
rates for consumer credit reports. And I hope that you will help us
to better understand what those error rates look like.
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Can each of you, to the best of your knowledge, tell the sub-
committee the error rates in your consumer credit reporting prod-
ucts with regards to each of the following categories and informa-
tion—trade lines, collections, inquiries, consumer identifying infor-
mation, and public records?
Did you all hear the question?
Hello?
Chairman GREEN. We heard you.
Ms. ADAMS. Oh, okay.
Chairman GREEN. To whom are you addressing your question?
Ms. ADAMS. To both—to Ms. Anderson and—
Chairman GREEN. We will start with Ms. Anderson.
Ms. Anderson, would you have a—
Ms. ADAMS. —and Mr. Danaher.
Ms. BEVERLY ANDERSON. There are two of us. Which Ms. Ander-
son?
Ms. ADAMS. Oh, okay. Oh, both Ms. Anderson’s and Mr.
Danaher.
Ms. BEVERLY ANDERSON. I will step in and go first. I would
agree. Accuracy is very, very important, and I shared my perspec-
tive a little bit earlier. I think there is a ton of work that has been
done across the years with furnishers clarifying the report, bring-
ing data accuracy into being, but I also believe that there is more
work that we can do as we all work to ensure maximum accuracy.
The data that you are asking for, I would be happy to follow up
with, but I just wanted to acknowledge that. I completely agree.
Ms. ADAMS. That will be fine, if you all would send that to us
in writing. Do we have any other responses or would you all—can
you all just send it to us in writing?
So let me ask you, if you do track these error rates, what are the
metrics used to track accuracy and the error rates in the consumer
data using your products and the frequency of such tracking? Mr.
Danaher, what about you?
Mr. DANAHER. Thank you, Congresswoman. We track those in
two ways. One is, we look at all of the disputes that we get from
consumers and we determine what the cause of the error was.
And as Ms. Anderson pointed out, we can get you that by cat-
egory, so we can follow up and report that data to you. The other
way that we track it is by looking at what data furnishers provide
us and error rates by data furnisher. So, if we find that we are get-
ting disputes from consumers at higher concentration from a par-
ticular data furnisher, we work with them to try and correct it.
If it can’t get corrected, as Ms. Anderson pointed out, we have
the same process. We will prevent that data furnisher from report-
ing data to us. So, we have statistics on both sides of that.
Ms. ADAMS. Okay. Good enough. Let me ask Ms. Wu, do you feel
that a new broad-based public analysis of the accuracy of and error
rates for consumer credit reports would be warranted to update the
important work the FTC undertook a decade ago?
Chairman GREEN. Ms. Wu, before you answer, please allow me
to intercede. We are beyond the 5 minutes. We will receive Ms.
Wu’s answer, and then the Chair will have to move on to the next
witness. The timer that we have, as Mr. Barr has indicated and I
agree, is inaccurate at this time.
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So Ms. Wu, if you will kindly answer, please?
Ms. WU. Yes, of course. Thank you, Chairman Green, and thank
you, Congresswoman Adams. I certainly agree that more data is al-
ways useful. If there is to be a study, it needs to be started right
now, because it took the FTC 10 years to do that study. It is in-
credibly intensive.
With respect to the furnisher reports that Mr. Danaher men-
tioned, they do have reports on different furnishers and how accu-
rate they are. And this committee may want to ask for those re-
ports because that gives one indication of accuracy and, of course,
the other indication is the massive number of complaints to the
CFPB. Thank you.
Chairman GREEN. The gentlelady’s time has expired.
The Chair will now recognize Mr. Mooney for 5 minutes.
Mr. MOONEY. Thank you, Mr. Chairman. These credit reports
give lenders an insight into how likely a borrower is to pay back
a loan. If the potential borrower has an incomplete credit history,
or a history of poor credit, then the prospect of payback is less cer-
tain. This results in higher pricing or even an unwillingness to ex-
tend credit at all.
In other words, [inaudible]—
Chairman GREEN. Mr. Mooney, would you please check to see if
you have muted yourself?
Mr. Mooney, we cannot hear you. Would you please check again
to see if you muted yourself?
Mr. MOONEY. Okay. It is not on mute. Can you hear me now?
Chairman GREEN. We can hear you now. Thank you. And I will
extend your time by 30 seconds.
Mr. MOONEY. Okay. Way to measure uncertainty. The more un-
certain the loan, the higher the price to compensate for the risk.
Mr. Danaher, can you please tell us what would happen to the
cost and availability of credit if we were to suppress adverse infor-
mation on credit reports?
Mr. DANAHER. Thank you, Congressman. I think two things
would likely occur in that case. First, the cost of credit would in-
crease as lenders priced, as you say, for the unknown, for the risk.
And second, I think there would be a contraction of credit. Lend-
ers would be less willing to lend to marginal borrowers because
they would not have that insight into exactly how that borrower
might perform.
So, I think that risk-based pricing does result in lower prices for
many consumers, but it also greatly expands the universe of poten-
tial borrowers because you are able to price appropriately for risk.
Mr. MOONEY. Got it. My next question is for Ms. Kuehn. Your
testimony listed past instances when either legislative or regu-
latory changes led to improved accuracy on consumer credit re-
ports. Do you have any policy recommendations to improve credit
report accuracy going forward?
Ms. KUEHN. We have seen a lot of work going on these last few
years, particularly with the advent of the Consumer Financial Pro-
tection Bureau. This was the first regulator with examination au-
thority.
So whereas, the FTC could investigate issues of accuracy, the ex-
aminers at the CFPB are down there daily looking at the oper-
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24
ations of the consumer reporting agencies and working with them
to find ways to improve accuracy.
This is an ongoing process that, frankly, is usually outside of the
public view and has made a lot of strides in improvements to the
processes and systems. This is why the CFPB announced recently
that they intend to undergo a new study on accuracies, since it has
been so long since the FTC study, and are they going to look at dif-
ferent methodologies, hopefully faster than the 10 years that Ms.
Wu referred to, to be able to conduct the study on this and look
for these improvements.
Mr. MOONEY. Thank you, Mr. Chairman.
I yield back the balance of my time.
Chairman GREEN. The gentleman yields back.
The Chair now recognizes the gentleman from Illinois, Mr. Gar-
cia, for 5 minutes.
Mr. GARCIA OF ILLINOIS. Thank you, Mr. Chairman, and Mr.
Ranking Member, and thanks to all of the witnesses. The reality
is that people in working-class communities like mine in the dis-
trict I represent worry a lot about their credit score. It is hard
enough to rent an apartment, get a job, or buy a house, and a low
credit score can lock people out of building a better future for them-
selves and their families.
In normal times, it is concerning, but right now, while Congress
and the White House are focused on building back better and pro-
moting an equitable recovery from the COVID-19 pandemic, these
barriers are a real policy problem. We talked today about the inad-
equacy of the dispute resolution process at the credit rating agen-
cies, and how an error on someone’s credit report can wreck their
financial future. But existing dispute processes are too automated
and frequently side with the lender or furnisher instead of the sub-
ject of the report.
We have known about this problem for years. I have a question
for the representatives from Equifax and Experian. Have your com-
panies worked together to address issues in your dispute resolution
process, and please be mindful that the clock is running pretty
quickly here?
Equifax, please?
Ms. BEVERLY ANDERSON. The dispute process is a very important
process for consumers, and we have three ways that a consumer
can engage with us around disputes—an online dispute process
which gives them the ability to track exactly where the dispute is.
They can dispute by our contact centers and by mail. We work di-
rectly as an intermediary with consumers, as well as with fur-
nishers to do our best to rectify and resolve that dispute quickly.
We actually have the ability, if we have the right information, to
resolve a dispute and assist a consumer without going through the
furnisher. We also can work directly with the furnisher through in-
vestigations. In 2015, we agreed with the other bureaus to work to-
gether to share cross information on disputes so that we do actively
compare and contrast notes and information so that we do a very
good job on behalf of the consumer. I look forward to—
Mr. GARCIA OF ILLINOIS. Can we let Ms. Sandy Anderson also
take a crack at that?
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Ms. SANDY ANDERSON. Thank you, Congressman. Similar to what
Ms. Anderson at Equifax stated, we have similar processes. We
continuously look at, how do we improve the dispute process, allow
consumers to reach out to us in their channel of choice, and we also
look for ways that we can resolve that dispute directly with the
consumer and/or going to the data furnisher.
Mr. GARCIA OF ILLINOIS. And have you discussed implementing
stronger standards across the industry to help decide when to in-
vestigate a claim made by a furnisher?
Ms. SANDY ANDERSON. As Ms. Anderson referenced, our coopera-
tion under the End Cap Agreement allowed for us to make im-
provements there and we continue to look at how do we do that as
an industry.
Mr. GARCIA OF ILLINOIS. Okay. Ms. Wu, do you think that the
industry takes dispute resolution issues like parroting seriously?
Can companies improve the dispute resolution process themselves
or do you think that an independent body or stronger standards
would help consumers straighten out issues?
Ms. WU. Thank you, Congressman Garcia. I think we need an
independent body. The incentives are always with the credit bu-
reaus to side with the furnishers. Those are their customers. The
idea that there is any competition for consumers, it doesn’t exist.
If I am unhappy with Equifax because they gave my data away
in the Equifax data breach, I still can’t walk away from Equifax.
We need an independent body, either an ombudsperson at the
CFPB and the FTC, or ideally, a public credit registry, because the
credit rating agencies’ incentive is just to sell this data as much as
possible. A public credit registry would give us a lot more control.
And one more thing, on this risk-based pricing issue, just remem-
ber, risk-based pricing caused the mortgage crisis of 2008–2009.
Mr. GARCIA OF ILLINOIS. Thank you very much. No further ques-
tions.
I yield back, Mr. Chairman.
Chairman GREEN. The gentleman yields back.
The Chair now recognizes Mr. Kustoff of Tennessee for 5 min-
utes.
Mr. KUSTOFF. Thank you, Mr. Chairman. And thank you for con-
vening today’s hearing, and I thank the witnesses for appearing.
If I could, we know that identity theft and breaches, of course,
have been well covered by this committee. I think one thing that
all three of the credit reporting agencies recommend for for individ-
uals to do are credit freezes.
And I will say to all of your credit, I think you have made the
process of requesting a credit freeze safe, you have made it reliable,
and while there are a number of checks and balances, it can be
done fairly expeditiously.
Mr. Danaher, if I could to you, the same is probably not true for
children, in other words, those under 18 years of age. My question
to you is—actually, two questions. One is, when would you rec-
ommend a credit freeze for a child?
And two, what, if anything, can be done by your agency and oth-
ers to make the process easier to request a credit freeze for a child?
And that is to Mr. Danaher.
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Mr. DANAHER. Oh, thank you, Congressman. Sorry. I didn’t hear
that.
Yes, we believe the process for adding a credit freeze to a minor’s
credit file or preventing a credit file from being opened for a minor
until they are of age—I think it is 16 on our system—can be made
easier, and we are currently wrestling with that right now. The
issue for us is proving who can set a freeze for a minor, in other
words, verifying the identity of the person trying to set the freeze.
So whether it is a parent, guardian, et cetera, like knowing the
relationship between the person trying to set the freeze and the
minor—currently, we have to ask for documentation on that, and
people submit manual documentation so that we can verify that it
is being set by the appropriate person.
But we are looking at ways to automate that and make it easier
for parents, guardians, et cetera, to protect the identities and the
credit files of their minor children.
Mr. KUSTOFF. If I could, to Ms. Anderson of Experian, I will ask
you the same question: Is there an easier way? Are you looking at
an easier process to place credit freezes for the benefit of children?
Ms. SANDY ANDERSON. There is always room for process improve-
ment, and we certainly take that seriously and continue to look at
it, but just as a reminder, the display of anybody under the age of
18 is blocked. So, that information would not go out of our systems
even if it was in the system of record.
Mr. KUSTOFF. Would the children still be at risk of identity theft
if the record was not frozen?
Ms. SANDY ANDERSON. There is always risk of identity theft with
fraudsters getting access to personal PII, but, again, getting access
to that data from our systems when we don’t release that data
until they are 18.
Mr. KUSTOFF. Thank you, Ms. Anderson.
And Ms. Anderson of Equifax, if I can ask you a different ques-
tion. I am referring back to your written testimony. You do note
that the credit scores during COVID hit an historic high. I think
you said it was around 710 or 711, and you cited some of the rea-
sons.
At Equifax, do you project over the next 6 to 12 months whether
that trend will continue?
Ms. BEVERLY ANDERSON. Certainly, we did, in fact, see credit
scores improve over the COVID timeframe, and we believe that as
long as the consumers have access to the kinds of protections that
we have seen during the CARES Act, we imagine that behavior
could, in fact, improve.
Of course, I don’t want to sit here and forecast what the future
looks like, but certainly we believe that the economy is recovering,
consumers feel positive about where things stand relative to
COVID, and jobs are starting to return. So, we definitely feel posi-
tive.
Mr. KUSTOFF. Thank you, Ms. Anderson. And thank you, Mr.
Chairman.
Chairman GREEN. The gentleman’s time has expired. The Chair
has an announcement. The Chair will step away, and in the ab-
sence of the Chair, the gentlewoman from Georgia, Ms. Williams,
the Vice Chair, will assume the position of Chair.
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I have Ms. Garcia of Texas next, then Mr. Timmons of South
Carolina, and thereafter, you would recognize yourself for 5 min-
utes. And perhaps I will be back before that time, but if not, you
will recognize me after you have recognized yourself.
I yield now to Ms. Garcia of Texas for 5 minutes, and Madam
Chairwoman, I shall return.
Ms. GARCIA OF TEXAS. Mr. Chairman and Madam Chairwoman
now, thank you for bringing us to talk about such an important
issue. This is an issue that I have heard a lot about going back to
my legal aid days when I had occasion to call the National Con-
sumer Law Center and I can say that they were always very help-
ful in getting through some of our client issues.
Credit scoring is a fundamental part of our economic system. A
person’s credit score determines their access into our financial mar-
ketplace. As I have said many times before, access to credit means
access to building wealth. This system is founded on the idea that
it is fair and accurate, but recently we found a series of problems
with disputes and inaccuracies.
While I realize that sometimes these things do happen, it is im-
portant that we get to the bottom of this to ensure that it doesn’t
happen to the degree that it hurts our consumers. Mine is a work-
ing-class district. Many people in my district, as consumers, don’t
understand the processes of the consumer credit agencies. They
don’t understand what credit scores mean, so it really, really keeps
them away from the marketplace.
Ms. Wu, I wanted to start with you. You have told us some of
the stories, and in my district, because it is a 77-percent Latino
district, with a very high population of Spanish-speaking persons
with limited English literacy, can you describe the various phrases
by those who prefer a language other than English and, more im-
portantly, what legal framework exists to protect those who are
subject to even more information challenges than the average con-
sumer?
Ms. WU. That is a great question. Thank you, Congresswoman
Garcia. The fundamental problem is this: Credit reports are not
available in languages other than English. We have sent letters to
the credit bureaus asking them, please, translate the credit report.
It should be easy in this day and age of automated translation and
then having someone go through it to check everything, and we got
a big, fat no from the credit bureau, and we got a no from CDIA,
that they wouldn’t translate the credit report.
How are you supposed to monitor and keep track of your credit,
check for errors, and dispute if you can’t even read the informa-
tion? Equifax, to its credit, did say they are looking into it, but oth-
erwise, a big, fat no.
Ms. GARCIA OF TEXAS. Let’s ask each one of them.
So Ms. Sandy Anderson, is it true that Equifax is thinking about
it or is already doing it?
Ms. SANDY ANDERSON. I represent Experian, Congresswoman,
but for us, we currently don’t offer credit reports in any other lan-
guage other than English. We do have Spanish-speaking agents
that consumers can reach out to and discuss their credit report and
questions, so we do provide that. We also work with different com-
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28
munity groups that provide financial education services in the con-
sumer’s native language.
Ms. GARCIA OF TEXAS. Okay. Now, let’s ask the other Ms. Ander-
son.
Ms. BEVERLY ANDERSON. Thank you, Congresswoman. We are
very close to launching our first Spanish credit report. We are ex-
cited about the work that we have been doing there. In the mean-
time, we have Spanish agents in our call centers and translation
language vendors who help us when we have consumers who need
additional support from a language perspective.
Ms. GARCIA OF TEXAS. Right. And the last one, Mr. Danaher?
Mr. DANAHER. Congresswoman, we do make credit reports avail-
able both in English and Spanish. We also have Spanish-speaking
customer support agents who will answer any questions somebody
may have in Spanish.
As we talked about when we met earlier this week, we are also
looking at prioritizing other languages and trying to figure out
what the demand might be for consumers to see their data in lan-
guages other than English and Spanish.
Ms. GARCIA OF TEXAS. To Ms. Tlaib’s point earlier when she was
asking some questions, there are studies that have found that
there is disparate treatment of minorities, and certainly the recent
complaint bulletin that was issued by the Consumer Financial Pro-
tection Bureau in April of 2021, just last month, clearly showed
that in 2020, the CFPB received more complaints per capita for
consumers living in predominantly minority counties, and from
2019 to 2020, complaints increased at a greater rate in predomi-
nantly minority counties compared to predominantly White, non-
Hispanic counties. It is there. We have to do something to do bet-
ter.
And with that Madam Chairwoman, I know my time is running
out. I want to ask for unanimous consent to submit for the record
a copy of the complaint bulletin outlining some of the items that
I just mentioned.
With that, I yield back.
Chairwoman WATERS. Ms. Williams, will you please take the
chairman’s chair and the gavel?
Ms. WILLIAMS OF GEORGIA. [presiding]. Thank you, Chairwoman
Waters. And thank you, Ms. Garcia, and your questions will be
submitted for the record.
Ms. GARCIA OF TEXAS. So, my document is approved for the
record?
Ms. WILLIAMS OF GEORGIA. Yes.
Chairwoman WATERS. Without objection, it is so ordered.
Ms. GARCIA OF TEXAS. Thank you, ma’am.
I yield back.
Ms. WILLIAMS OF GEORGIA. The Chair now recognizes Mr.
Timmons from South Carolina for 5 minutes.
Mr. TIMMONS. Thank you, Madam Chairwoman.
First, I want to point out that risk-based pricing definitively did
not cause the financial crisis of 2008. In fact, it was the absence
of accurate risk-based pricing. The distortionary influence of gov-
ernment policies subsidizing credit in ways that concealed the real
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29
credit risk that encouraged lenders to put people in homes with
mortgages they couldn’t afford. I just wanted to begin with that.
So now, I have an actual question. Given the data breaches in
the past and, particularly, the ransomware attack involving Colo-
nial Pipeline, I would imagine cybersecurity is top of mind for your
institutions. Can you describe the increased security posture you
all have put in place after the Equifax breach, and briefly describe
your efforts to make sure that all consumer credit information is
kept safe and secure?
And any one who wants to answer that?
Ms. BEVERLY ANDERSON. Why don’t I start, since you referenced
the Equifax breach?
Mr. TIMMONS. Okay. Thank you.
Ms. BEVERLY ANDERSON. Thank you for that question, Congress-
man.
I would like to say that Equifax is certainly focused on security
and we believe that the work we have done over the course of the
last several years puts us at the forefront of being an industry
leader in security. We spent a billion and a half dollars over the
last 3 years delivering top notch security and IT infrastructure into
a cloud native environment and multi-millions of dollars creating
a security response and monitoring system.
We have hired a number of cybersecurity experts in our company
and we have made security a core tenet to our culture as a com-
pany. Most recently, we produced a report sponsored by security
experts called, ‘‘Bright Site,’’ which indicated that our company is
in the top 3 percent of security of the top 1,000 largest U.S. firms.
So, we are excited about the work we have done to secure our
customers’ and our consumers’ data.
Mr. TIMMONS. Sure. Thank you for that. And I will open this up
to anyone else. My second question is going to be about the increas-
ing patchwork framework of data privacy and security regulations
at the State level across the United States.
Are your companies concerned that privacy and security compli-
ance costs are going to increase, and would you prefer Congress to
preempt States to create one nationwide standard?
Ms. KUEHN. I will take that one. Thank you for the question. A
nationwide standard would make it easier to figure out when con-
sumers need to be notified in the event of a breach, but all of the
consumer reporting agencies comply with Federal standards for
data security to ensure the security of information no matter where
consumers are located.
Mr. TIMMONS. Thank you. Would either Experian or TransUnion
want to weigh in on that as well?
Ms. SANDY ANDERSON. Thank you, Congressman. Yes, we would
support a Federal privacy law.
Mr. DANAHER. Congressman, yes. We agree, too. It is easier for
us and more productive to manage the one standard rather than
40 or 50.
Mr. TIMMONS. Sure. Thank you. When you consider your cyberse-
curity budgets, do you also include the associated compliance costs?
I don’t want to get into that right now, but we might send some
follow-up questions. I would love to understand more because when
considering your cybersecurity budget, that should be a part of it.
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30
And when you have to hire an army of attorneys to comply with
all of the various privacy and data security regulations, it really
adds up. So, I appreciate that.
Quickly, before I close, I do want to respond to the gentlewoman
from Michigan, Ms. Tlaib, who was litigating the practice of auto
insurers using credit scoring data in their underwriting. The aver-
age auto insurance rate in Michigan is $2,300 a year, versus just
$1,500 a year in South Carolina where this underwriting factor is
used. Insurance is a highly regulated business on the State level.
South Carolina’s best, what our market and consumers need, not
Congress, and definitely not anyone from Michigan.
With that, I yield back. Thank you.
Chairman GREEN. The gentleman yields back.
The Chair thanks the Vice Chair for standing in, in my absence.
The Chair is now honored to recognize the Vice Chair, Ms. Wil-
liams, for 5 minutes.
Ms. WILLIAMS OF GEORGIA. Thank you, Mr. Chairman. According
to a recent CFPB consumer complaint bulletin, consumer com-
plaints rose across-the-board between 2019 and 2020, but at an
even faster rate in predominantly non-White counties. Earlier this
month, I offered and passed an amendment on the House Floor
that will study this kind of disparity and provide policy rec-
ommendations to ensure greater equity.
Ms. Wu, how important is it to analyze and address racial dis-
parities to advance the broader goal of creating a more consumer-
friendly financial marketplace?
Ms. WU. It is absolutely critical, and it is probably the most im-
portant issue facing credit reporting and credit scoring, the fact
that there are vast racial disparities in credit scores.
The Urban Institute found that more than 50 percent of White
households have a FICO score above 700, compared to only 20 per-
cent of Black households. That is why risk-based pricing hurts
Black consumers more, that is why these practices of using credit
scores for auto insurance hurts Black consumers more, and that is
why errors affect minority communities more because folks who
have lower credit scores are more prone to errors in their credit re-
port, and that makes sense.
If you have an 800, that means you have a perfect credit record;
you are not going to get errors. And so, the racial disparity should
be top of mind for anybody who cares about racial justice.
Ms. WILLIAMS OF GEORGIA. Thank you, Ms. Wu.
Also, in your testimony you mentioned how important it is to
take the pandemic’s impact into account when it comes to negative
credit reporting. Currently, the law provides that a Federal student
loan borrower’s credit score can’t be negatively affected if they miss
the Federal student loan payment during the pandemic, but this
protection was made possible with bipartisan support.
I recently worked with my colleague, Congresswoman Alma
Adams, to pass an amendment to provide student loan borrowers
the same relief from private student loans. How would providing
all student loan borrowers equitable relief and credit reporting dur-
ing the pandemic help everyday folks who have experienced finan-
cial disruption and are struggling to get back on their feet?
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31
Ms. WU. It certainly would help—borrowers with private student
loans should have the same protections as borrowers with Federal
loans. And, in fact, the CARES Act protection didn’t even cover all
borrowers with Federal loans, and so it is important that all of
them got relief given the economic dislocation caused by the pan-
demic.
I also note that slipping through the cracks definitely happened
with Federal student loan borrowers. There was a lawsuit against
one servicer, Great Lakes, for messing up the credit reporting. That
is why we advocated for a moratorium on negative information dur-
ing the pandemic, because of the severe nature of the economic dis-
location. The CARES Act provisions are complicated and we have
definitely seen a lot of creditors mess up on them.
That is actually what the slipping through the cracks is, that Ms.
Beverly Anderson warned has been happening.
Ms. WILLIAMS OF GEORGIA. Thank you so much, Ms. Wu.
And with that, Mr. Chairman, I yield back.
Chairman GREEN. The gentlelady yields back. And the Chair now
recognizes Mr. Gottheimer for 5 minutes.
Mr. GOTTHEIMER. Thank you, Chairman Green, for allowing me
to attend this important hearing. And thank you to our witnesses
for being here today.
The United States is the most credit fraud-prone country in the
world. Every year, 15.4 million Americans are victims of credit card
fraud or around 42,000 people every single day. The FTC has found
that one in five consumers have verified errors in their credit re-
ports and one in 20 consumers have errors so serious that they
have been denied credit or forced to pay higher interest rates. That
adds up to 42 million Americans with errors on their credit and an-
other 10 million with errors that can be life-altering.
Scams increase during times of crisis, and COVID-19 has been
no exception.
As the nation works into the economic recovery from the reces-
sion brought upon by the crisis, I think we can all agree it is more
important than ever that all Americans have equal and just access
to credit.
Ms. Anderson, early into the pandemic your company, Experian,
joined TransUnion and Equifax in announcing that Americans
would be able to access their credit report for free on a weekly
basis. Knowing that Americans would be under significant stress
from keeping their families and communities safe and worrying
about their jobs, why did you your company still choose not to give
Americans unlimited free access to their reports?
Ms. SANDY ANDERSON. Congressman, thank you for that ques-
tion. We do provide access to free credit reports on a weekly basis
as an industry. Experian also provides free credit monitoring, free
access to credit reports, and free credit scores to over 40 million
U.S. consumers today, and we continue to grow that as consumer
needs rise.
Mr. GOTTHEIMER. So, you are doing exactly what TransUnion
and Equifax offer?
Ms. SANDY ANDERSON. I can’t speak for the other two, but cer-
tainly Experian is expanding our free offering to consumers.
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32
Mr. GOTTHEIMER. So during the pandemic, everyone has been
able to access their credit for free on a weekly basis?
Ms. SANDY ANDERSON. Correct.
Mr. GOTTHEIMER. Okay. That is good.
Ms. Wu, you have been concerned, particularly during the pan-
demic, about credit issues and Americans having access to informa-
tion about their credit?
Ms. WU. What we have been concerned about is the impact of the
pandemic on consumer’s credit reports and their credit records, es-
pecially debt collection items.
We had heard that scores [inaudible] And risen. It is due to a
number of things. One is the fact that you have case sheet recov-
ery. So, if you have some scores that go up and some scores that
go down, on average, you may get the same scores or a slight up-
tick, but what I am worried about is the 8 to 10 million renters
who are facing eviction, who may then face debt collection items for
back rent. That is going to hurt their credit reports.
Also, medical debt. A lot of people lost their employer-provided
health insurance. When you get medical debt, you get debt collec-
tion items. They sharpen your credit report, and they hurt your
ability to get credit, to get housing, and to get employment.
So, these are some of the things I worry about. I do commend the
credit bureaus for providing free credit reports once per week. I
think it should be permanent. You had a bill last year that would
provide something similar to that, and I think it is a great idea.
Mr. GOTTHEIMER. Thank you so much. I am glad we got a chance
to work together on these issues.
Do you agree that we should make it easier for Americans to get
their information for free, and initiate disputes when it comes to
credit, given how important this credit information can be in every
aspect of people’s lives, from what they pay for insurance to their
mortgage, you name it, it seems to be affected by people’s credit
scores?
Ms. WU. Absolutely. It should be easy and it should be fair. Easy
should mean not just the credit reports, but the scores. You need
the credit scores to know where your credit standing is. And it
shouldn’t be just the one credit score that lenders use the most
often; it should also be other risk scores.
The credit bureaus are developing all of these new products and
these new scores that judge consumers. All of those should be
available, not just the regular credit score, but healthcare scores,
fraud risk scores, and tenant screening scores.
And then, it should be fair. When you dispute, you should be able
to get a fair determination, one that doesn’t always side for the fur-
nisher, and that is why the ombudsperson concept in your bill last
year was so important to give the CFPB the ability to be the ref-
eree when the consumer disagrees with the results.
Mr. GOTTHEIMER. Exactly. I think you are referencing the Pro-
tecting Your Credit Score Act. It creates an online portal, as you
know, to provide Americans with free, unlimited access to their
credit reports, credit scores, credit freezes, the ability to dispute er-
rors and fraud, and the ability to secure and track their credit
data. All of that transparency to help Americans boost their credit
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33
and financial security through economic declines and beyond, and
it is clear we still need this legislation.
And you are making a great point about making sure that it is
all the scores, not just ones they can create other ways around.
Thank you so much, and I thank the witnesses for being here
today.
And thank you, Mr. Chairman.
Chairman GREEN. The gentleman’s time has expired.
The Chair now recognizes himself for 5 minutes for questions.
Permit me to ask the witnesses to comply in the following fash-
ion: I shall pose a question, and I will ask that you simply raise
your hand if you understand the question as I have posed it or if
your answer is to be yes or no, and I will be sure to be clear as
to whether I want you to raise your hand if it is yes or no.
Let me ask first—and I assume that you are very much aware
of this given that you are at the hearing—were you aware of the
title of this hearing today? The title is, ‘‘Consumer Credit Report-
ing: Assessing Accuracy and Compliance?’’
Were you aware of the title of the hearing prior to coming today?
If so, would you kindly raise your hand? Thank you very much.
Let the record reflect that all of the witnesses were aware, prior
to today. Now, is it true that as a major business, you maintain
records so that you can ascertain the accuracy rate that you have
within your business? If you believe that as a major business, you
should do this, would you kindly raise your hand, maintain your
accuracy rate?
Okay. Thank you very much. All of the witnesses agree that they
should maintain an accuracy rate.
Would you kindly now tell me what your accuracy rate is? Let
me start with you, Ms. Sandy Anderson.
Ms. SANDY ANDERSON. Thank you, Mr. Chairman. We track a
number of metrics to determine accuracy rate, and right now, we
are tracking at over 99 percent.
Chairman GREEN. And what metric was that, please?
Ms. SANDY ANDERSON. That is our accuracy metric that we use
to track material errors in credit reports as they are used by lend-
ers and consumers.
Chairman GREEN. Am I to understand that with reference to
your errors, you are not 100-percent accurate in terms of the infor-
mation that you provide?
Ms. SANDY ANDERSON. Correct.
Chairman GREEN. Thank you very much.
Let’s go to Mr. Danaher. The question is the same to you, sir.
Mr. DANAHER. Mr. Chairman, our analysis shows that credit re-
ports are 98-percent accurate with regard to material accuracy. So,
2 percent or so of credit reports are inaccurate, with material con-
sequences for the borrower.
Chairman GREEN. Thank you.
Let me move now to Ms. Beverly Anderson.
Ms. BEVERLY ANDERSON. The last accuracy data measured by the
CFPB happened in 2012. We know that there is another report
that they would like to have to update the accuracy data, and we
welcome that study. We have a number of measures in our busi-
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34
ness that measure the accuracy of our data furnishers, the level of
dispute—
Chairman GREEN. Ms. Anderson, I will have to intercede. I need
to know what your accuracy rate is. You have acknowledged that
you knew what we were going to discuss today, and you are saying
that 2012 data probably is a little bit outdated, but what is your
accuracy rate, please?
Ms. BEVERLY ANDERSON. Our data will be similar to the other
two bureaus.
Chairman GREEN. What does similar mean in terms of a number,
please?
Ms. BEVERLY ANDERSON. I will have to get back to you with the
number.
Chairman GREEN. I would ask that you do so, and I express my
dismay that you are not prepared, given that you were well-aware
of the title of this hearing and what we would be asking.
Let me go on to something else that is exceedingly important.
Minorities seem to have higher inaccuracy rates or error rates than
others in this business. Do you keep a record of the accuracy rate
as it relates to minorities?
Let me start with you, Ms. Anderson, do you keep such a record?
Ms. Beverly Anderson, can you hear me?
Ms. BEVERLY ANDERSON. Yes, I can.
Chairman GREEN. Do you keep such a record, and I will ask that
you respond—
Ms. BEVERLY ANDERSON. Yes. We do not have race data on our
file.
Chairman GREEN. Let me move on to Mr. Danaher.
Mr. DANAHER. No, Mr. Chairman. We don’t have any insight into
the race of the people on the credit file with regard to accuracy.
Chairman GREEN. And then, Ms. Sandy Anderson.
Ms. SANDY ANDERSON. Thank you, Mr. Chairman. No, we don’t
have race data in our credit file either.
Chairman GREEN. My time has expired.
Let me thank the witnesses for their testimony, and for devoting
the time and resources to share their expertise with the sub-
committee. Your testimony today will help to advance the impor-
tant work of this subcommittee and of the U.S. Congress.
The Chair notes that some Members may have additional ques-
tions for this panel, which they may wish to submit in writing.
Without objection, the hearing record will remain open for 5 legis-
lative days for Members to submit written questions to these wit-
nesses and to place their responses in the record. Also, without ob-
jection, Members will have 5 legislative days to submit extraneous
materials to the Chair for inclusion in the record.
I would also, while it is after the fact and a little bit late, remind
Members that we are not to address our comments to other Mem-
bers, but rather to the Chair.
With that said, this hearing is now adjourned.
[Whereupon, at 1:56 p.m., the hearing was adjourned.]
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APPENDIX
May 26, 2021
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File and source
- File
- CHRG-117hhrg45079.pdf
- Size
- 54,140,957 bytes
- SHA-256
- dd04d336eff38da92efde1524cf059d3424e0295c0b3348395aff77239af5284
- Our copy
- CHRG-117hhrg45079.pdf
- Original
- www.govinfo.gov