Demand for FFIEC Advisory Letter Requiring the Reporting of Credit Card LIMITS to CRAs

Target attached the 1/18/2000 Federal Financial Institution Examination Council (FFIEC) Advisory Letter as exhibit to its Motion for Summary Judgment, claiming that it acknowledges that furnishers of credit information such as Target are not required by the FCRA to report credit limits to the credit bureaus. I am demanding a new Advisory Letter requiring that all creditors report the credit limits.

(LITIGATION NEWS) September 12, 2005

To:

Daniel Pearson, National Bank Examiner, Credit Risk Division, Office of the Comptroller of the Currency
Serenca Owens, Examination Specialist, Division of Supervision, Federal Deposit Insurance Corporation
Arleen Lustig, Supervision and Regulation, Board of Governors of the Federal Reserve System
Donna Deale, Manager, Credit Risk and Affiliate Policy, Office of Thrift Supervision
Janet I. Langston, Program Officer, National Credit Union Administration
Federal Financial Institution Examination Council

Re:  Immediate update to the FFIEC 1/18/2000 Advisory Letter with the requirement to report credit limits to CRAs

Ladies and Gentlemen:

I am suing Capital One and Target for their refusal to report the credit limits.  Target submitted your 1/18/2000 FFIEC Advisory Letter to the court with its Motion for Summary Judgment and wrote on pg. 6, ln. 5:

“Both the press release and the Advisory Letter acknowledge that furnishers of credit information such as Target are not required by the FCRA to report the high credit limit for consumer credit card accounts to the CRAs.”

On 8/16/04, I responded to the FTC’s request for public comments regarding the credit scoring study ordered by Congress, posted at http://fight-back.us/forum/index.php?s=&showforum=24. I address the importance of the reporting of the credit limits and the damages to the individual consumers as well as extremely negative impact on the economy due to consumer defaults.

Please issue a new Advisory Letter, requiring that all furnishers report the correct credit limit for all revolving accounts to the CRAs by Friday, 9/16/05.

It is a crime against humanity to condone the illegal exploitation of many MILLIONS of disadvantaged through the artificial lowering of credit scores by not reporting extremely important data such as the credit limits.

This open letter is posted at http://mylitigation.net/ and other websites.  The general public needs to know why more and more people end up in poverty.  It’s time we hold legislators and regulators accountable for their actions and in-actions.  Hopefully many others will publish their complaints in an effort to expose the corruption rampant at all levels of government and especially in the finance industry.

Sincerely,

Christine Baker
christine@bayhouse.com

The 1/18/2000 FFIEC Press Release:
http://www.ffiec.gov/press/pr011800.htm

The 1/18/2000 FFIEC Advisory Letter:
http://www.ffiec.gov/press/pr011800a.htm

The 8/9/2005 Target Motion for Summary Judgment:
http://forum.creditcourt.com/discus/messages/4781/4875.html

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Update 9/15/05:

I had called all the people listed, but only got their voice mails and left messages with detailed info about my letter twice.  I did get the fax number 202-927-0861 for Daniel Pearson with the OCC.  I faxed the printout to him, he ignored me.

I received a call back from Brendan Burke, who apparently now has the number listed for Arleen Lustig.  He doesn’t know her and he has nothing to do with this FFIEC Advisory Letter.

I also got a call on behalf of Serena Owens from Rick Schwartz, attorney for the FDIC at 202-898-7424.  He advised that I need to contact the executives at each agency to request a new FFIEC letter. 

Why don’t the individuals who signed the Letter forward my request to whoever is in charge? 

This shows how powerful Capital One is and how corrupt these “public servants” really are.