I would accept an amendment to the FCRA to specifically require the reporting of credit LIMITS only if all else fails, as it will cause numerous NEW problems:
EVERY time a creditor or collector finds it advantageous to OMIT reporting certain data, you have to get Congress to amend the FCRA!
Obviously, data furnishers will then argue that all required data must be specified in the FCRA.
This is already a problem with collectors who do NOT report the open date, do not report the name of the original creditor, etc.
As credit scoring software continually changes and new scores are developed, data furnishers can lower the consumers' scores by withholding data.
I already documented that data furnishers intentionally report incorrect and incomplete:
*** Capital One and Target don't report the credit limits.
They make it difficult or impossible for their customers to get accounts with their competition with better terms, lower rates, more benefits, etc.
*** Many collectors report collections as OPEN (no date closed) and currently delinquent accounts INSTEAD of closed accounts in collections.
While FICO scores are barely lowered by accurate and complete reporting of OLD collections, the collections reported as open accounts can lower the credit scores by over 50 points.
From the FCRA: [the 2004 version of the FCRA posted by the FTC including the FACT Act revisions]
§ 623. Responsibilities of furnishers of information to consumer reporting agencies [15 U.S.C. § 1681s-2]
(2) Duty to correct and update information. A person who
(A) regularly and in the ordinary course of business furnishes information to one or more consumer reporting agencies about the person's transactions or experiences with any consumer; and
(B) has furnished to a consumer reporting agency information that the person determines is not complete or accurate, shall promptly notify the consumer reporting agency of that determination and provide to the agency any corrections to that information, or any additional information, that is necessary to make the information provided by the person to the agency complete and accurate, and shall not thereafter furnish to the agency any of the information that remains not complete or accurate.
[Note: Consumers can NOT sue for section a) violations! Only regulators (who do NOTHING!) can enforce this section. Consumers must have claims under section b) (after dispute with a CRA) to be able to sue.]
(b) Duties of Furnishers of Information upon Notice of Dispute
(1) In general. After receiving notice pursuant to section 611(a)(2) [§ 1681i] of a dispute with regard to the completeness or accuracy of any information provided by a person to a consumer reporting agency, the person shall
(A) conduct an investigation with respect to the disputed information;
(B) review all relevant information provided by the consumer reporting agency pursuant to section 611(a)(2) [§ 1681i];
(C) report the results of the investigation to the consumer reporting agency;
(D) if the investigation finds that the information is incomplete or inaccurate, report those results to all other consumer reporting agencies to which the person furnished the information and that compile and maintain files on consumers on a nationwide basis; and
(E) if an item of information disputed by a consumer is found to be inaccurate or incomplete or cannot be verified after any reinvestigation under paragraph (1), for purposes of reporting to a consumer reporting agency only, as appropriate, based on the results of the reinvestigation promptly–
As you can see, the FCRA mandates COMPLETE reporting.
There is absolutely no reason to not report the extremely important credit LIMIT.
You need to understand that creditors like Capital One and many collectors will always do whatever they can to maximize their profits.
There is no way that I will start a new campaign every time I find that data furnishers came up with a new way to lower scores by NOT reporting certain data.
So if we need an AMENDMENT of the FCRA to define "complete", it should merely be added to the DEFINITITIONS that "completeness" means that all data relevant to underwriters or credit scores must be reported. It could also mention the CDIA's reporting guidelines, but as they are subject to change, I'm not sure.
It would definitely prefer to see legislators provide their opinion and explaining their intentions when they wrote the FCRA:
Complete means COMPLETE.
I'm confident that I can prevail on APPEAL and resolve not only the credit limit reporting problem, but ALL problems related to completeness.
It is incredibly easy to document the devastating impact of Capital One's refusal to provide the credit limits to many MILLIONS of consumers.
If you think that Congress will amend the FCRA every time one or two consumers can document a problem, well, I really hope that nobody thinks that it would happen.
In the interest of conserving our time and the legislators' time, we really ought to make sure that the issue of COMPLETE reporting is permanently resolved.