CCMC Comments on CFPB's Proposed Rule Implementing Amendments to the Fair Credit Reporting Act

The Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to comment on the Consumer Financial Protection Bureau (“CFPB”) proposed rule implementing amendments to the Fair Credit Reporting Act prohibiting inclusion of adverse information in consumer reporting in cases of human trafficking. We fully support implementation of regulations, as prescribed by the Debt Bondage Repair Act, to help survivors of human trafficking improve their financial standing and regain financial independence. We consequently support the determination made by Congress and reflected in the Debt Bondage Repair Act, that adverse credit information resulting from human trafficking is not predictive and should not be included in credit reports. In short, consumers who are survivors of human trafficking should not experience negative credit reporting due to crimes committed against them.