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December 7, 2004

Joel Winston
Associate Director
Financial Practices Division
Bureau of Consumer Protection
Federal Trade Commission
600 Pennsylvania Ave. NW
Washington, DC 20580

            Re:            Free Annual Credit Report Site is Blocking Web Links

Dear Mr. Winston:

We write to urge you to take immediate action to fix an anti-consumer, baseless practice implemented by the credit reporting agencies.  Congress required the national credit reporting agencies to operate a free, central source for obtaining credit reports.  They have done so, but in creating the site, http://www.annualcreditreport.com/, the credit reporting agencies have blocked web links from reputable consumer sites such as Privacy Rights Clearinghouse (http://privacyrights.org/) and Consumers Union (http://consumer.org), and from mainstream news web sites.  If one clicks on a link from a consumer or news site to the Congressionally mandated free credit source, the following error message appears:

For security purposes, www.AnnualCreditReport.com can be accessed by typing the web address "www.annualcreditreport.com", or from links from the Federal Trade Commission (www.ftc.gov), Equifax (www.equifax.com), Experian (www.experian.com) and TransUnion (www.transunion.com) websites.
AnnualCreditReport.com is the only web source authorized by all three nationwide consumer credit reporting companies from which free annual credit file disclosures can be requested.

In the interests of prompt action, we have written briefly below why this practice violates the Commission's regulations, why it is an anti-consumer practice that is not justified by security concerns, and why it makes it harder for individuals to find the free report site.  We urge you to direct the credit reporting agencies to unblock these web links immediately. 

Whether intentional or not, every subtle and not so subtle web design tactic has been employed to make www.annualcreditreport.com difficult to find and use.  It appears this is unlikely to have occurred by accident, because many of the tactics represent bad web design, mistakes that only beginner HTML authors would make.

Again, we urge you to take immediate action on this matter.  In passing the Fair and Accurate Credit Transaction Act of 2003, Congress intended that individuals have free, convenient access to their credit files.  The credit reporting agencies are frustrating Congress' intent, and it is incumbent on the Commission to immediately address this problem.



Chris Jay Hoofnagle
Associate Director
Electronic Privacy Information Center

Norma Garcia
Special Projects Staff Attorney
Consumers Union

Edmund Mierzwinski
Consumer Program Director

Beth Givens
Executive Director
Privacy Rights Clearinghouse

Evan Hendricks
Privacy Times

Brad Scriber
Housing Coordinator
Consumer Federation of America

Enclosures (3)

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Last Updated: December 7, 2004
Page URL: http://www.epic.org/privacy/fcra/freereportltr.html