There is nothing wrong with providing the consumer a copy of the consumer's own credit report. In fact, they have a right to request it.
It is true that the CRAs have historically had subscriber contract provisions making subscribers promise not to show the subscriber version credit report copies to the consumer/applicant. The FTC addressed, in an Informal Staff Op Letter, a question from a subscriber as to whether it violated law to allow the consumer to see it or have a copy. The FTC said it is not illegal. The question is whether the provision is contra bonos mores [against public policy] and ought to be illegal if enforced against a subscriber. Though the consumer might lack standing, the subscriber may be wrongfully cut off from services by the CRA for other ostensibly legitimate reasons after-the-fact. Some subscribers still sell to the consumer. Recently I addressed this issue when speaking to a
Bar group. A former FTC lawyer claimed that no such contractual provisions existed. I offered to show her a contract on the spot and she backed down.
The problem is that the CRAs sell a different report to the subscriber than the consumer. The consumer version has LESS information contrary to CRA industry's claim to the contrary. They want to conceal the report and claim that you cannot prove your credit denial damage or defamation claim if you cannot get the lender to show you the report [or tell the truth about its contents]. The reason the reports differ goes back to the method of inquiry, in large part.
A "consumer disclosure" [credit report copy] is generated with "complete" ID info so the report is restrictive in content and presumably more accurate.
The subscriber version can be accessed through inputting minimal ID data.
Further, the matching program engaged for each is different. The disclosure program requires stricter matching compliance [points of correspondence], while the subscriber access is "looser" requiring less points.
What results is a 1681e[b] violation in the subscriber version report. The disclosure report, oddly, will comply with 1681g. Think about it.
David A. Szwak, Esq.
http://www.MyFairCredit.comhttp://www.MyFairDebt.com