NCLC and CSAJ submit this petition for rulemaking under the FCRA to the CFPB asking the Bureau to:
- modify the definition of “identity theft” to include “without effective consent” to provide relief for victims of coerced debt and specify what constitutes effective consent;
- modify the definition of “identity theft report” to reflect the modified definition of “identity theft”;
- allow the modified definition of “identity theft” to enable victims of coerced debt to utilize the block of information resulting from identity theft; and
- clarify that no CRA, including specialty CRAs, can refuse to block information under 15 U.S.C. §1681c-2(c)(1)(C) if the consumer is a victim of coerced debt.