Pilot Study 2 on Processes for Determining the Accuracy of Credit 

Bureau Information

Performed for the Federal Trade Commission 

Under Contract FTC07H7185 

 By 

L. Douglas Smith, Ph.D. 

Thomas H. Eyssell, Ph.D. 

Chloe Gray-LeCoz, B.A. 

Luigi Wewege 

The Center for Business and Industrial Studies 

University of Missouri-St. Louis 

One University Blvd. 

St. Louis, MO 63121 

Tel: (314) 516-6108 

Fax: (314) 516-6827 

 

Michael E. Staten, Ph.D. 

Financial Services Research Program (FSRP) 

The George Washington University Business School 

Duques Hall, Suite 551 

2201 G Street, NW 

Washington, DC 20052 

Tel: (202) 994-0884 

 

Jeffrey Feinstein, Ph.D. 

Fair Isaac Corporation 

3550 Engineering Drive, Suite 400 

Norcross, GA 30092 

Tel: (770) 710-8116 

Fax: (770) 810-8381 

October 15, 2008 
a

Pilot Study 2 on Processes for Determining the Accuracy of Credit 

Bureau Information 

Executive Summary 

The purpose of this pilot study is to refine and test research methodology for a national 

study on the accuracy of credit-bureau information in accordance with Section 319 of the 

Fair and Accurate Credit Transactions Act of 2003 (FACTA). This second pilot study 

was undertaken to see if a more efficient procedure could be employed to recruit and 

register participants than the sequential use of direct mail, telephone screening, mailed 

consent forms, and e-mail for registration instructions that were employed in the first 

pilot study. A second major objective was to see if explicit involvement of the 

researchers in preparing paperwork for filing disputes would result in a more complete 

investigation of possible errors in participants’ credit files than would occur if all dispute 

activity were the responsibility of the participant. Again, consumers were engaged in 

thorough reviews of their credit reports and credit scores from the three major U.S. credit 

bureaus (Equifax, Experian and TransUnion). In cases where a consumer identified items 

that he or she believed to be reported erroneously, and where such items might have an 

adverse effect on the consumer’s eligibility for credit, terms of credit (or expose the 

consumer to some credit-related risk such as identity theft), the research team assisted in 

the filing of formal disputes. The research team also tracked the outcomes of disputes by 

drawing new credit reports from the relevant bureaus after an appropriate delay to allow 

revisions to appear. 

A secure internet research website was designed and implemented at the University of 

Missouri-St. Louis for providing information about the study, obtaining reproducible 

electronic consent, registering participants, and providing registered participants with 

vouchers for acquiring credit reports through the Fair Isaac myFICO.com website. 

Cooperating financial institutions informed a sample of their customers about the 

opportunity to participate in the study and referred them to the study website for 

additional information and registration. The study website created substantial 

efficiencies in recruitment over the direct mail approach used in the first pilot study. 

Referral of customers from financial institutions to the study website proved to be a 

highly effective channel that we would recommend for the national study. 

Purely random selection of potential invitees is found again to produce a distribution of 

volunteering consumers with higher credit scores (and therefore, as explained in our 

report, a possibly lower incidence of errors in credit reports) than present in the national 

universe of consumers. A weighted random sampling approach, whereby more 

invitations are extended to groups of consumers who are likely to have lower credit 

scores would be necessary to produce a nationally representative sample. A limited test 

of this in a mailing to credit-union members produced a sample closer to national norms. 

Direct recruitment of individuals engaged in a nonprofit program for assistance in 

income-tax preparation, though more labor-intensive, was demonstrated to be another 

effective tactic for engaging individuals with a more challenging credit history and lower 
b

credit scores. A combination of weighted random sampling and recruitment through 

social service agencies would likely prove effective in the national study. 

The pilot study produced refined survey instruments, organizational tools and analytical 

structures for the national study. It demonstrated the value of facilitative mechanisms 

(especially a study website) for obtaining signed consent and authorizing the drawing of 

credit reports. It also demonstrated how additional involvement of the research team to 

prepare the paperwork for disputes results in a higher proportion of cases in which 

disputes are filed, and therefore in a more penetrating investigation into the accuracy of 

the credit-bureau data. We recommend providing such support for the national study, 

while recognizing that doing so makes it impossible to assess the likelihood that 

consumers alone will initiate a dispute to address various types of error with the support 

system currently in place. 

In sum, the basic research procedures employed in the pilot studies are found again to be 

suitable for use in a study of national scale. They allow participants to be engaged 

without revealing their Social Security numbers or specific account numbers to the 

research team, and thus protect the privacy of personally identifying information. They 

enable thorough investigations of the integrity of credit-bureau information, provide data 

for estimating the frequency and severity of errors in existing files, and provide useful 

information about the workings of the dispute-resolution process. 

We must emphasize again that, while we provide illustrative statistics from the pilot 

study to show the type of information that may be garnered with this research 

methodology, a much larger and more representative sample would be required to 

estimate the percentage of consumers nationwide who would similarly dispute the 

accuracy of information in their credit files. Furthermore, to generate a nationally 

representative sample (or sufficient numbers in a stratified sample for adjusting error 

rates to account for different response rates), it will be necessary to employ mechanisms 

such as weighted random sampling and targeted outreach to engage sufficient numbers of 

individuals with low credit scores. 

 
Table of Contents 

Study Background and Purpose .... Page 1 

Study Methodology .... Page 2 

 

Yields from Alternative recruiting Channels .... Page 11 

Characteristics of the Sample .... Page 17 

Illustrative Findings .... Page 20 

 

Implications for the Conduct of the National Study .... Page 27 

Planning Parameters for the National Study .... Page 28 

Acknowledgements .... Page 30 

Exhibits 
List of Exhibits 

Exhibit 1 – Solicitation and Referral Letters for Recruiting and Engaging 

Participants (Exhibits 1A through 1E) 

Exhibit 2 – Illustrations of Internet Website Screens for Providing Study 

Information, Issuing Reproducible Electronic Consent, and Registering 

Study Participants 

Exhibit 3 – Checklist for Consumer to Prepare for In-Depth Review 

 of Credit Reports 

Exhibit 4 – Sample Spreadsheet for Cross-Bureau Comparisons of 

 Key Elements in the Credit Reports 

Exhibit 5 – Interviewing Guide for In-Depth Review of Credit 

 Reports 

Exhibit 6 – Sample Letters Prepared for Consumer to Facilitate Filing a 

Dispute (Exhibits 6A through 6E) 

Exhibit 7 – Follow-up Survey to Assess the Process, Obtain Demographic 

Data and Confirm Dispute Outcomes 

Exhibit 8 – Offer of Expedited Review for Participants with Clean Credit 

History 

Exhibit 9 – Questionnaire for Expedited Review 

Exhibit 10 – Contents of SAS Database Created to Summarize CreditBureau Information and Outcomes for Each Participant 
1

Pilot Study 2 on Processes for Determining the Accuracy of Credit 

Bureau Information 

Background and Purpose 

This study is an extension of a pilot study conducted successfully in 2005-2006 to test the 

feasibility of engaging consumers in a comprehensive review of credit reports derived 

from the three major U.S. credit bureaus (Equifax, Experian and Trans Union). These 

pilot studies were undertaken to help prepare the FTC to conduct a national study of 

consumer information in major credit-bureau files in accordance with Section 319 of the 

Fair and Accurate Credit Transactions Act of 2003 (FACTA). The purpose of the 

national study is to determine the prevalence and severity of errors in the three major 

national credit-report repositories and the impact of those errors on representations of 

consumers’ creditworthiness. 

In the first pilot study, the research team found that, with proper support, consumers can 

be engaged for an intensive review of the accuracy of information in their credit reports, 

and the research process was found to produce the relevant data necessary for an 

objective analysis of the accuracy of information contained in the credit-bureau files. 

There were, however, two significant issues that merited further investigation before 

undertaking the national study. First, there was a greater representation among the 

participants of consumers with very high credit scores than consumers with very low 

credit scores. In designing the sampling plan for a national study, it would help to know 

what kind of representation may be expected to emerge from different recruiting channels 

so that necessary adjustments could be planned to produce nationally representative 

results. Second, some participants failed to complete the necessary paperwork to file 

disputes despite alleging that errors were found in their credit reports. Additional support 

seemed necessary to encourage the filing of disputes when warranted. 

In this second pilot study, the research team developed and tested streamlined processes 

for recruiting consumers, obtaining reproducible electronic consent to the terms of 

engagement, registering disputes when relevant, assessing the impact of alleged errors on 

consumers’ credit scores, and following the results of the dispute process. The goal was 

to complete the process for 100-120 participants and determine: 

1. The effectiveness and efficiency of alternative recruitment channels for acquiring 

a representative sample of consumers in a national study 

2. Whether preparation of dispute letters by the research team for review and 

execution by the consumers would improve follow-through in cases where there 

were allegations of potentially material errors in the credit reports 

3. Whether a weighted stratified sampling plan would produce greater representation 

of consumers with low credit scores (whose reports are statistically more likely to 

contain errors), thus reducing the need for statistical adjustments for imbalanced 

representation when generalizing from the study to the universe of records in 

national repositories of credit data 

4. Whether direct outreach to underrepresented segments of the population who lack 

internet access and computer is practicable in a study of this nature. 
2

Based on findings from the extended pilot, the research team offers further 

recommendations to the FTC regarding the design of a national study to obtain unbiased 

estimates of the prevalence and severity of errors in the three national credit-report 

repositories. Finally, the study provides information about methods of sampling and 

analysis that may be employed to compensate for a greater inclination of persons with 

higher than normal credit scores to volunteer to participate. 

In this report we describe the new recruitment process and methods employed to increase 

efficiency while still protecting consumers’ private information. We furnish illustrations 

of computer web-pages and printed materials used to manage the recruitment process and 

guide the review of credit reports. We provide examples of correspondence generated for 

the participants to file disputes and describe the process for following up on disputes. 

Specifically, we investigate whether changes are made to the credit reports following the 

filing of consumer disputes and what the impact of those changes would have been on the 

consumers’ credit scores. We illustrate the contents of the resulting research database and 

provide sample reports for analyzing the frequency of alleged errors and their impact of 

measures of consumers’ creditworthiness. We provide statistics on yield and attrition at 

each stage, and discuss other issues that will need to be addressed in the conduct of the 

national study. 

Study Methodology 

The relevant population consists of adult members of households to whom credit has 

been extended in the form of credit cards, automobile loans, home mortgages and equity 

lines, or other forms of installment credit. Recruitment of individuals who met these 

criteria occurred through several channels involving: 

1. Direct-mail solicitation with telephone follow-up to household addresses obtained 

from published telephone directories and public municipal records (the process 

used in the first pilot study). 

2. Two cooperating financial institutions (Navy Federal Credit Union and 

Commerce Bank) whose executives wrote personal letters to randomly selected 

clients to inform them about the study and referred their clients to the study 

website for detailed information and registration. 

3. Personal contact with clients of a community-based voluntary income tax 

preparation (VITA) program with multiple sites (primarily public libraries) in the 

St. Louis metropolitan area. 

Recruiting and Engaging Participants 

Introductory information about the study was conveyed via a letter from Dr. Peter Vander 

Nat on behalf of the FTC (Exhibit 1A). In both the direct mail solicitations and on a 

specially designed study internet website (ftcstudy.umsl.edu), Dr. Vander Nat’s letter 

outlined the purpose of the study and encouraged participation of an adult with credit 

history that can be checked in databases of national credit bureaus. Navy Federal Credit 

Union and Commerce Bank, the two cooperating financial institutions, sent letters to 
3

inform a small sample of their members and customers about the study and referred them 

to the study website. Copies of the financial institutions’ referral letters are provided in 

Exhibit 1B and Exhibit 1C respectively. Samples of other correspondence from the 

research team to study participants are in Exhibits1D through 1E. 

The study website (ftcstudy.umsl.edu) was constructed and administered at the University 

of Missouri-St. Louis to provide information to potential participants about the study 

itself and the nature and obligations of their engagement. Exhibit 2 contains a series of 

snapshots of the screens presented at the internet website. After verifying that they have 

read the materials and understood the terms of engagement, consumers can register for 

the study (with verifiable electronic consent), receive a voucher for obtaining the credit 

reports with credit scores from each of the three credit bureaus through Fair Isaac’s 

myFICO.com website, and be referred automatically to myFICO.com to compete the 

transaction. Participants were given a logon ID to use for the myFICO account and, 

through the website, they provided the research associates a password that could be used 

for printing the credit reports. To protect confidentiality of consumer data and to prevent 

its misuse, digits of the participants’ Social Security numbers (SSNs) and digits of all 

account numbers are suppressed by Fair Isaac in the computer screens and printed reports 

containing the credit-bureau data. 

The UM-St. Louis study website was constructed to function in secure mode with nonpersistent “cookies” (meaning that the information entered in the registration process 

would be erased from memory on the participants’ computers at the conclusion of their 

session). Links were provided to the respective website security policies of each of the 

research partners (UM-St, Louis, the FTC, Fair Isaac Corp., and George Washington 

University), data security protocols were described, and the website was constructed to 

allow handicapped access and verified to meet P3P standards, which ensure that the 

user’s browser can detect whether the privacy policy of the website is consistent with the 

user’s own privacy settings and preferences. The Federal Trade Commission also 

performed an assessment of the registration website, as required by the E-Government 

Act of 2002. See, Registration Web Site for the FACTA Credit Report Accuracy Study—

Privacy Impact Assessment (February 2008). The latter may be accessed at: 

http://www.ftc.gov/os/2008/02/080228pia.pdf. 

The website enabled the arrangements to be completed by participating consumers 

without divulging their social-security numbers to members of the research team. 

Participants provided reproducible electronic consent that authorized the University to 

obtain credit reports with credit scores from the three major U.S. credit bureaus and to 

review them in detail. Consenting individuals were also asked, in the confirming e-mail 

generated by the website, to sign and mail a hard copy of the consent form to the 

University. 
4

Review of the Credit Reports 

University research associates used the accounts established by the consumers with Fair 

Isaac at myFICO.com to print copies of current credit reports with credit scores. One 

copy of the reports was mailed to the consumer’s home address along with a brochure 

describing the content and meaning of information in the credit report and with a 

checklist to guide them in review of the credit reports for accuracy (Exhibit 3). Another 

copy was retained by the University for succeeding steps in the study. Fair Isaac was 

informed when reports were drawn so that a frozen copy of the credit file as of that date 

could be saved for possible revision and rescoring if a consumer should allege that it 

contained some error. The process then proceeded with the following steps: 

1. University research associates thoroughly reviewed the information in each of the 

credit reports and organized it in spreadsheets (Exhibit 4) designed to prepare for an 

in-depth review of the information with the consumer. Apparent inconsistencies 

between the bureau records were noted for further review. 

2. An in-depth telephone interview (see guide in Exhibit 5) was conducted with the 

participant to review the credit reports and to identify possible errors. Where 

discrepancies were alleged, participants were informed whether the type of alleged 

error could have a significant impact on their credit scores (and therefore possibly 

affect their access to or cost of obtaining further credit). They were also alerted to 

whether an inaccuracy may affect actions from other uses of credit-bureau 

information (such as employment or insurance) or suggest a risk of identity theft. 

3. The research associates employed an agreed set of decision rules (described later) to 

identify instances where the alleged errors should be considered as potentially 

material. In cases with potentially material errors (and in others where the consumers 

wished to correct alleged errors that seemed immaterial), the research associates 

prepared documentation (letters) for filing of disputes, using support available for the 

relevant bureaus through the myFICO website. 

4. Changes were marked on the University’s copies of relevant credit report(s) to 

“correct” alleged errors and, if meeting the materiality criterion, a copy of the 

changed pages was mailed to Fair-Isaac for re-scoring of the frozen file. 

 

Filing Disputes and Determining the Results 

5. Consumers completed the dispute letters prepared by the research associates by 

adding their SSNs, signing the letters and mailing them to the appropriate parties. 

They returned a prepaid postcard to the University verifying that they had posted the 

dispute letters (see Exhibit 6 A-E). 

6. In instances where material changes in a credit score occurred from rescoring of a 

frozen file, (i.e., changes beyond normal cross-sectional variation in credit scores 

among the three agencies or changes that would take consumers over traditional 

thresholds for credit decisions), and in cases where other material errors (such as an 

allegation of erroneous merging of information from another consumer’s file), a 

credit report was obtained by the University approximately six weeks after the filing 

of the dispute (giving sufficient time for the dispute to receive the proper attention). 
5

7. Resulting changes were noted and recorded in the research database. 

Option of Expedited Review with Written Verification of the Accuracy of Data 

It became apparent in the course of the study that consumers with a clean credit history 

(no late payments or other derogatory entries) and with consistent information in each of 

the three bureaus’ files, are very often able to review their reports quite quickly and the 

result of each of the first 70 reviews of this type was a report of no alleged errors in each 

case. In the last month of the study, the research team proposed to Dr. Vander Nat that 

we experiment with an expedited process for obtaining consumers’ written verification 

that their credit reports are accurate. The motive for this experiment was to facilitate 

closure with some individuals who were hard to reach for the in-depth telephone 

interview, perhaps because they had reviewed their credit reports, found that they were 

accurate, and saw no potential benefit in reviewing the reports in detail with the research 

team. In the last month, the research team therefore sent a letter from the FTC (Exhibit 

8) to participants with clean credit history and no identifiable inconsistencies among data 

provided by three credit bureaus, offering them the opportunity to verify that they had 

checked the information with the help of the checklist provided and found no 

inaccuracies. The letter was mailed to individuals to whom credit reports had been 

mailed at least two weeks previously and with whom the research associates had been 

unable to schedule interviews despite at least three attempts to reach the individuals by 

telephone and e-mail. A prepaid return envelope and questionnaire (Exhibit 9) were 

provided by which the participant could report the results of their own review and 

provide the demographic information used to characterize the samples. We emphasize 

that this option was offered only to individuals with a clean credit history and with 

consistent information reported by all three credit bureaus. This offer was extended 

to 16 individuals. Within one week of mailing the letter, five recipients called to arrange 

a brief telephone interview to complete the process. One of the five reported an 

immaterial error regarding an incorrect address; the remaining four found no errors in 

their credit reports. Four (4) expedited closing surveys were received by mail confirming 

that the participant found no errors. The expedited processes yielded a total of nine (9) 

out of sixteen (16) or 56.3%. 

In Figure 1, we provide a flowchart of the study process and indicate the number of 

cases in the pilot study that were involved on each path. On the first page of Figure 1, we 

see that 142 participants were engaged. Credit reports with accompanying materials were 

mailed to these 142 individuals and 142 analytical spreadsheets were prepared for the 

telephone reviews. Sixteen (16) offers for expedited review were extended. Five (5) of 

these 16 individuals opted to undergo the telephone review; four (4) reported by mail that 

their credit reports were accurate. Telephone reviews were conducted with 124 

participants (with reviews pending for 14 participants as of October 10, 2008). From the 

124 cases for which the review of the credit records was completed by the participants 

over the telephone, there were 84 instances where there were no alleged inaccuracies in 

any of the bureau files and the process stopped for those individuals at that point. A total 

of 88 cases were closed with no errors alleged (84 with telephone review and 4 with 

confirmation of no errors in writing via the expedited process). 
6

142 0

142 0

142 0

142 0

16 YES

 

NO

126

(7) 5 NO

(7)

YES

4 124

84 NO YES 40

88

88

88

Participants register 

at 

"ftcstudy.umsl.edu"

Participants register 

at "myfico.com"

Reports are pulled 

from "myfico.com" 

and mailed to 

participants

Reports are 

analyzed and 

prepared for review

Reports are 

reviewed with 

participant

Error 

alleged

Closing survey

Database update

Error process

Process 

complete

Offered 

expedited 

review

Written

confirmation 

of no errors

 

 

Figure 1 - Flowchart of the Study Process 
7

Figure 1 (cont.) Flowchart of the Study Process (Cases with Alleged Inaccuracies) 

15 

40

25 NO YES 15 15

25 15

4 NO YES 21

4 NO YES 11

25

11 NO YES 4

15

25

25 15

12

14

12

12

12

Error Process

Potentially 

material

Dispute paperwork 

is drawn and sent to 

participant

Postcard 

received

Follow-up phone 

call/e-mail

Closing survey

Database update

Dispute paperwork 

is drawn and sent to 

participant

Postcard 

received

Follow-up phone 

call/e-mail

Confirmation from 

participant that 

disputes received 

by credit bureau

New report is drawn 

and analyzed

Results are recorded

Closing Survey

Process complete 

with database 

update

Dispute paperwork 

is sent to FairIsaac 

for rescoring

Re-score is received

Process 

complete

Process 

complete

25 

12 

4
8

The other 40 cases were subjected to further review (second page of Figure 2) to 

categorize the errors and proceed through the dispute process, where appropriate. Each 

of these 40 cases was subjected to the materiality test and dispute paperwork was 

prepared in all 40 instances. In 15 of the 40 cases with alleged inaccuracies, there was 

the possibility of a material effect on the credit score, and the frozen credit report was rescored by Fair Isaac. A second credit report was drawn six weeks after the dispute letters 

were sent to the credit bureaus (for 15 participants in the pilot study) and a detailed 

analysis of the materiality of errors and consequences of disputes was performed for 

these cases. 

Training of the Research Associates 

Thorough preparation by the research associates who conduct the in-depth reviews with 

consumers is essential for an effective review of the credit reports and protection of 

consumers’ privacy. The principal investigators first familiarized the research associates 

with the process employed in the first pilot study and the information that is gathered to 

assess the accuracy of credit-bureau data. The research associates were familiarized with 

the data protection protocols for the study and certified as having taken the University’s 

training program for researchers dealing with human subjects. 

Using credit reports from the first pilot study (from which all personal identifying 

information had been redacted), the Principal Investigators acquainted the research 

associates with the detailed information in the credit reports and the data used to produce 

the credit scores. Members of the research team next participated in a one-day training 

program conducted by Dr. Jeffrey Feinstein from Fair Isaac in which he also reviewed 

the information in credit-bureau files, explained how various items contribute to an 

individual’s credit score, and addressed questions about how various hypothetical 

changes in credit-bureau data would likely affect one’s credit score. The research 

associates had access to Fair Isaac Corp. online training materials and helpline staff to 

address questions that arose in the course of the study and they had continual contact with 

the Principal Investigators to discuss specific issues as they arose. 

Preparation for the Review of Individuals’ Credit Reports 

Before each interview, the research associates performed a careful review and crosscheck of information available in the three credit reports and summarized them in a 

spreadsheet to facilitate the interview. They checked: 

• current name, address and date of birth 

• previous names and addresses 

• employment history 

• active accounts 

• accounts with nonzero balances 

• negative items (e.g., number and severity of reported delinquencies) 

• derogatory public records (e.g., bankruptcy) 

• total outstanding account balances including 

o mortgages 
9

o installment loans 

o revolving credit (home equity loans, revolving accounts and credit cards) 

• inquiries in connection with credit applications 

• length of credit history 

• specific mortgage amounts and current balances 

• automobile loans with origination amounts and current balances 

• other installment credit with origination amounts and current balances 

• specific open revolving accounts with credit limits and current balances 

• number of accounts that have been submitted for collection 

• total amounts that have been submitted for collection 

• current balances on accounts under collection. 

These are the key items from the credit reports that are used to assess creditworthiness 

and therefore would be expected to be reflected in the consumer’s credit scores. In 

addition, the research associates computed summary statistics (such as credit utilization) 

from the detailed data and compared them with values summarized in the credit reports. 

In preparing the spreadsheet, the research associates started with information from the 

credit bureau that had the greatest amount of information on file (often the one with the 

lowest credit score), and then extracted corresponding information and complementary 

information from the other bureaus’ reports. The resulting spreadsheet (Exhibit 4) 

facilitates a comparison of the critical information in the reports from the three bureaus 

and complements the checklist mailed to the consumer with their copies of the credit 

reports. 

 

Normal Variation in Bureau Reports 

The Fair Credit Reporting Act does not require creditors to report to all bureaus. Care 

was therefore taken to inform the consumer that all creditors do not report to all bureaus 

and that we were therefore concentrating on the presence of erroneous information in a 

file, rather than trying to identify information that could have been reported to the 

bureaus but which was not reported. We also reminded them that the bureaus could send 

reports at different stages in a billing cycle and that they may therefore be reporting an 

account balance for a different day of the month. Consumers were generally quite adept 

at recognizing these normal variations and validating the information reported for open 

accounts with balances. 

Accounts with zero balances pose some difficulty to consumers (and the researchers) 

because sometimes they had been closed and re-established with a different name or 

account number (as after a corporate acquisition or report of stolen credit card). The 

credit bureaus do not use uniform and unambiguous descriptors for such events and there 

was sometimes uncertainty as to whether an account should be considered to be currently 

open when computing the consumer’s total line of credit on revolving accounts. 

When it appeared that the credit scores could be affected by “correcting” the alleged

errors, the research associates marked the credit reports with explanations of the 
10

discrepancies and sent copies of the marked reports to Fair Isaac for rescoring. The 

purpose of rescoring was to identify cases where the creditworthiness of the borrower 

might have been materially misrepresented (i.e., where access to credit or terms of credit 

may have been significantly affected if the alleged errors were substantiated and not 

corrected). The criteria used in selecting a report with alleged inaccuracies that might 

potentially have a material impact on a credit score (and therefore subject to rescoring) 

were: 

1. Credit score less than 760 (a cutoff widely used to identify consumers with 

lowest credit risk and for extending credit on most favorable terms) AND 

a. alleged error in number of negative items (such as late payments), or 

b. alleged inaccurate number of public derogatories, or 

c. alleged error in number of accounts sent to collection, or 

d. alleged error in number of inquiries for new credit (hard pulls on the file), 

or 

e. alleged error in outstanding balances not attributable to normal monthly 

reporting variation, or 

f. allegations of accounts on the report not belonging to the client, or 

g. duplicate entries of the same information (such as late payments or 

outstanding obligations) that were double-counted in reported summaries 

of such items. 

Results of rescoring were not shared with the consumers. 

A summary record of the in-depth review and subsequent outcomes was inserted into a 

SAS (Statistical Analysis System) dataset for research and reporting purposes. The SAS 

record contained no identifying consumer information except the randomly generated ID 

that was used for the myFICO log on id (without password), the birth-date for computing 

the age of the consumer, the gender of the participant, ZIP code of residence and standard 

demographic characteristics obtained from the closing survey to characterize the 

composition of the sample. Items placed in the research database and derived from the 

data for analytical purposes are listed in Exhibit 10. 

Measures to Protect Individual Consumer Data 

Digits in the participants’ social security number and account numbers are suppressed by 

Fair Isaac in the credit reports to ensure that no unauthorized use of account information 

can occur. A unique identifier (myFICO account number) was assigned to associate data 

with study participants. Copies of the printed credit reports were secured in a locked 

filing cabinet in an office dedicated to the project and credit reports were printed on a 

dedicated printer in that office. Access to the printed reports and the detailed data therein 

was limited to the University researchers and to trained professionals at Fair Isaac Corp. 

who imposed tentative revisions for rescoring of the frozen credit files. Only summary 

information (such as number of credit accounts, outstanding credit balances and credit 

scores) was reported and used in statistical analysis of study outcomes. 
11

Time Burden for Participating Consumers 

Some consumers prepare thoroughly in advance of the interview and enabled a review of 

even complicated situations to be done in an interview of 15-20 minutes. Other 

consumers did not find the time for significant preparation in advance of the telephone 

review. In such cases the interview took longer (20-50 minutes), often involving 

explanations of how negative items in the credit report might affect the credit score, or 

why inter-bureau differences arise in the credit scores. In every case in the pilot study, 

the review was able to be completed to the satisfaction of both the consumer and the 

research team. The interviews themselves took an average of 19 minutes. The median 

time was 15 minutes, with 90 percent taking between 5 and 45 minutes. The participants 

reported taking an average of 69 minutes (median of 53 minutes), with 90% taking 

between 10 and 180 minutes) to prepare for the interview. 

Yields from Alternative Recruiting Channels 

Planning for the national study requires estimates of the percentage of individuals that are 

likely to register for the study when informed of the opportunity through a particular 

recruiting channel; it also requires an indication of the likely distribution of credit scores 

that will naturally emerge from each channel. We pay particular attention to the 

distribution of credit scores, because the credit score is a comprehensive measure of 

creditworthiness that may be used for stratifying the analysis of reported errors and 

judging how representative the sample is of the universe of credit records. Taking into 

account the differences in reported error rates and dispute outcomes for consumers in 

different credit-score tiers, one may adjust estimates of average error rates to account for 

imbalance in a sample. 

Recruiting for the study began with a direct-mail solicitation to 203 addressees spread 

throughout the United States. The process was effectively the same as employed in the 

first pilot study. Written consent to terms of participation was obtained from consumers, 

and they were given purchase vouchers and instructions for opening their accounts at the 

Fair Isaac website. This enabled the research team to initiate data collection with a 

familiar bench mark while negotiating arrangements and creating the infrastructure to 

receive referrals from financial institutions or other cooperating parties. 

After the study website was created and tested, all further registration occurred through 

the study website (Exhibit 2). Successive waves of mailings were scheduled with the 

cooperating financial institutions and invitations were extended through information 

circulars and direct contact at VITA (Volunteer Income Tax Preparation Assistance) 

service sites in the St. Louis metropolitan area. Participation of VITA clients was limited 

to 10 (10% of the minimum number of participants to be engaged in the study). Intensive 

follow-up to recruit participants from the direct mailing stopped after the website was 

active, as the prime purpose of this pilot study was to examine the effectiveness of 

recruiting participants through referrals from financial institutions and other channels. 
12

Yields from the various recruiting channels and the status of cases with completed 

reviews as of October 9, 2008 (six weeks after closure of registration of participants) are 

summarized in Table 1. The information is segmented according to recruitment channel 

and phase as follows: 

1. Direct mail to a nationwide random sample from published telephone directories 

and public records 

2. Navy Federal Credit Union Mailing 1 to a randomly selected sample of 500 

members 

3. Navy Federal Credit Union Mailing 2 to another 500 members selected with 

greater concentration on individuals expected to have very low credit scores than 

on individuals expected to have very high credit scores. This was to test whether 

such selection would create a more balanced representation of credit scores. 

4. Navy Federal Credit Union Mailing 3, to another 500 members. 

5. Commerce Bank Mailing 1 to 500 customers via a glossy insert with the monthly 

billing statement announcing an opportunity to participate in the study as an 

offering from the bank’s Marketing department. 

6. Commerce Bank Mailing 2 to 2000 customers via a separate letter announcing the 

opportunity to participate as an offering from the bank’s Customer Service 

department. 

7. Invitations to VITA clients extended through circulars at counseling sites and 

through personal contact 

8. Miscellaneous engagement of associates of the participating financial institutions 

and a prospective large employer (approached as an alternative channel but not 

used, as our quota had been reached) to demonstrate and test the website and 

study process in the developmental stages while contributing to the results. 

The last line in Table 1 shows the outcomes for cases following the completed reviews of 

the credit reports. In 31.3% of the reviewed cases, there were allegations of inaccuracy 

in at least one of the three credit-bureau reports. In 11.7% of the cases, an alleged

inaccuracy met the materiality threshold adopted for the study and required followthrough with pulling of a new credit report to determine the outcome from a formal 

dispute. 
13

Table 1 - Yields from Alternative Recruitment Channels and Status of Reviewed 

(based on Data through September 17, 2008) 

Recruiting Channel Letters 

Sent 

Consents

Rec’d. 

Reports 

Drawn 

and 

Mailed 

Reviews 

Done 

Cases with 

Alleged 

Inaccuracies 

Cases with 

Potentially 

Material 

Disputes 

C

O

Direct mail 203 13 12 12 7 3 Navy Federal Mailing 1 500 25 25 24 11 4 Navy Federal Mailing 2 500 19 19 17 5 2 Navy Federal Mailing 3 500 8 8 7 2 0 Commerce Bank Mailing 1 500 7 7 7 0 0 Commerce Bank Mailing 2 2,000 48 48 39 9 3 VITA N/A 10 10 9 4 3 Miscellaneous N/A 19 13 13 2 0 Total 149 142 128 40 15 Subsequent status of cases with completed reviews 100% 31.3% 11.7% 
14

The patterns of engagement were not uniform among the recruiting channels. To 

illustrate the differences, we next examine the involvement and retention at each stage of 

the research protocol that occurred through the individual recruiting channels. This will 

enable us better to produce a set of parameters for estimating the extent (and nature) of 

outreach required to produce a sample of the desired size in a national study. For each 

channel, we report: (1) the number of consumer contacts that were initiated and the 

number of consumers (participants) who progressed to the next stage of the study process 

(2) the marginal percentage of consumers who progress from each stage to the next stage, 

(3) the cumulative percentage of attempted consumer contacts who are engaged at each 

successive stage, and (4) the cumulative percentage of registrants for the study that 

reach each of the successive stages. 

Direct-mail recruiting yield, dispute rates and completion rates. Letters were mailed 

to 203 prospects (see Table 2). The research associates made personal telephone contact 

with 100 of the targeted consumers (49.3%) and 25 (25.0%) of those reached expressed 

interest in participating. Of those 25, 13 (52.0%) provided signed consent; 12 of the 13 

(92.3%) established accounts at Fair Isaac for purchasing the credit reports. Reviews 

were completed with all 12 individuals (100%) to whom credit reports were mailed. 

Dispute paperwork was prepared for 7 of the 12 participants (58.3%), but only 3 of the 7 

(42.9%) of the cases with alleged inaccuracies involved an item at one of the bureaus that 

met one of the materiality criteria. The cumulative effects of attrition at each stage are 

illustrated in the last two columns. The yield of participants from the direct-mail 

initiative was 5.9% of consumers to whom a letter was mailed. Dispute paperwork was 

prepared for 3.4% of prospects and 58.3% of participants. Follow-through to test the 

outcomes of disputes that met the materiality criterion was required for 1.5% of the 

prospects and 25.0% of participants. 

Table 2 – Involvement at Successive Stages for Direct Mail Recruits 

Stage in Research Protocol Number Marginal 

Percent 

Cumulative 

Percent of 

Outreach 

Cumulative 

Percent of 

Participants

Letters mailed 203 100 100 NA 

Telephone contact made 100 49.3 49.3 NA 

Expressed interest in 

participating 

25 25.0 12.3 NA 

Provided signed consent 13 52.0 6.4 NA 

Established accounts 12 92.3 5.9 100 

Purchased credit reports 12 100.0 5.9 100 

Completed in-depth review 12 100.0 5.9 100 

Dispute paperwork prepared 7 58.3 3.4 58.3 

Material Disputes filed 3 42.9 1.5 25.0 

Dispute outcomes determined 3 100.0 1.5 25.0 
15

Credit-union recruiting yield, dispute rates and completion rates. In all, Navy 

Federal Credit Union mailed letters to 1,500 members (see Table 3). This resulted in 

participation of 52 consumers (3.5% of those informed about the study and referred to the 

website). Credit-report reviews were successfully completed for 48 of the 52 registrants 

(92.3%) and dispute paperwork was prepared in 18 of the 48 reviewed cases (37.5% of 

reviews). In 6 of the 18 cases with alleged errors, (33.3%), follow-up was required to 

determine the results of disputes that met the materiality criteria. Over all, 34.6% of 

participants alleged that there was some inaccuracy in one of the bureau reports and 

11.5% of the participants identified an alleged inaccuracy that met our threshold for 

materiality. 

Table 3 – Involvement at Successive Stages for Referrals from Navy Federal 

Credit Union 

Stage in Research Protocol Number Marginal 

Percent 

Cumulative 

Percent of 

Referrals 

Cumulative 

Percent of 

Participants

Letters mailed 1,500 100 100 NA 

Registered electronically 52 3.5 3.5 100 

Credit reports mailed 52 100 3.5 100 

Completed in-depth review 48 92.3 3.2 92.3 

Dispute paperwork prepared 18 37.5 1.2 34.6 

Material Disputes filed 6 33.3 0.4 11.5 

Dispute outcomes determined 6 100 0.4 11.5 

Bank recruiting yield, dispute rates and completion rates. In all, Commerce Bank 

mailed letters to 2,500 customers (see Table 4). This resulted in participation rates of 55 

consumers (2.2% of those informed about the study). Credit-report reviews were 

completed for 46 of the 55 registrants (with others still pending as of October 15). This 

number provided the targeted number of 120 participants and leaves the possibility of 

expanding the pilot sample to the total of 142 individuals for whom credit reports were 

drawn. Dispute paperwork was prepared in 9 of the 46 reviewed cases (19.6%). Of 

those, only 3 (33.3%) met one of the materiality criteria. Follow-up was thus required to 

determine the results of disputes that met the materiality criteria in 3 of the 46 reviewed 

cases (6.5%). One of the three confirmed sending dispute letters to the credit bureaus by 

returning the postcard enclosed with the dispute material (see Exhibit 6E).
16

Table 4 – Involvement at Successive Stages for Referrals from Commerce Bank 

VITA Recruitment. Recruitment and involvement of participants at the volunteer 

income tax preparation (VITA) sites has a dramatically different profile (see Table 5). 

Nine (9) reviews were completed for this targeted group; dispute paperwork was prepared 

in 4 cases of the 9 (44%) and follow-through for determining the results of disputes that 

met one of the materiality criteria was required in 3 of the 9 cases (33%). 

Table 5 – Involvement at Successive Stages for VITA Referrals 

This segment of the population was much more labor-intensive to serve. A higher 

proportion of the reports contained negative items; a higher percentage required the 

preparation of dispute letters and follow-through for potentially material disputes. Of the 

four cases where dispute paperwork was sent to participants, only one of the four 

participants returned the postcard indicating that the dispute had been registered with the 

Stage in Research Protocol Number Marginal 

Percent 

Cumulative 

Percent of 

Referrals 

Cumulative 

Percent of 

Participants

Letters mailed 2,500 100 100 NA 

Registered electronically 55 2.2 2.2 100 

Credit reports mailed 55 100 2.2 100 

Completed in-depth review 46 pending pending pending 

Dispute paperwork prepared 9 19.6 pending pending 

Material Disputes filed 3 33.3 pending pending 

Dispute outcomes determined 0 pending pending pending 

Stage in Research Protocol Number Marginal 

Percent 

Cumulative 

Percent of 

Referrals 

Cumulative 

Percent of 

Participants

Letters mailed to previous 

clients 

50 100 100 NA 

Paper consent received 4 8.0 8.0 NA 

Registered from direct mail 2 50.0 4.0 NA 

Registered electronically (all 

sources) 

10 NA NA 100 

Credit reports mailed 10 100 NA 100 

Completed in-depth review 9 90.0 NA 90.0 

Dispute paperwork prepared 4 44.4 NA 40.0 

Material Disputes filed unsure unsure NA unsure 

Dispute outcomes determined 3 pending NA 30.0 
17

relevant credit bureau(s). In two cases, we received no confirmation that the dispute was 

filed, but all of the requested changes had been imposed, for both participants, on the 

credit reports drawn later. We have been unable to reach the non-responsive individuals 

by phone to see if the paperwork had been mailed. 

Other participants. Finally, we have classified 13 participants in a miscellaneous 

(other) category. This group consists of individuals employed by potential referring 

institutions who were invited to experience the process as participants themselves before 

informing their associates and referring them to the study website for information and 

registration. This enabled us to test the website at progressive stages of development and 

to have executives of the respective organizations refer their clients with assurance that 

some of their employees had first-hand experience with the process, They could then, 

with comfort, vouch for the potential benefits afforded study participants with full 

understanding of the elaborate measures taken to protect the consumers’ personal 

information. Among these cases, there was a single instance where a dispute letter was 

prepared. It did not reach the materiality threshold. 

Table 6 – Involvement at Successive Stages for Other Participants 

Characteristics of the Resulting Sample 

The credit scores themselves and the demographic information provided by the 

consumers enable us to characterize the composition of the sample. We use the 

distribution of credit scores as a primary indicator of the extent to which the sample 

composition is representative of the universe of credit scores maintained by the bureaus. 

The demographic data help us assess the extent to which the sample is reasonably 

representative of the universe of consumers affected by bureau data. The distributions of 

credit scores in the sample appear for two different groupings in Table 7 and Table 8. 

Stage in Research Protocol Number Marginal 

Percent 

Cumulative 

Percent of 

Participants

Letters mailed NA NA 

Registered electronically 13 NA 100 

Credit reports mailed 13 100 100 

Completed in-depth review 13 100 100 

Dispute paperwork prepared 1 7.7 7.7 

Material Disputes filed 0 0 0 

Dispute outcomes determined NR NR NR 
18

Table 7 -- Distribution of Credit Scores for Participants 

Score Range Bureau A

(percent) 

Bureau B

(percent) 

Bureau C

(percent) 

Total 

(percent) 

Under 610 11 

(8.7) 

9 

(7.0) 

10 

(7.8) 

30 

(7.8) 

610-689 13 

(10.2) 

13 

(10.2) 

14 

(10.9) 

40 

(10.4) 

690-749 25 

(19.7) 

23 

(18.0) 

22 

(17.2) 

70 

(18.3) 

750-789 47 

(37.0) 

32 

(25.0) 

26 

(20.3) 

105 

(27.4) 

790 plus 31 

(24.4) 

51 

(39.8) 

56 

(43.8) 

138 

(36.0) 

The score ranges in Table 7 were selected to approximate the quintiles in the universe of 

FICO credit scores that emerge in the process of calibrating the credit-scoring models. A 

representative sample of credit bureau reports would thus be expected to have 

approximately equal numbers of scores in the respective groups. The actual distributions 

that emerged in the pilot sample indicate that we had a strong tendency to engage 

individuals whose credit histories produce higher than average credit scores. 

Table 8 – Comparison of Score Distributions for Fixed Intervals in Credit Scores 

Score Range Sample

percent

Bureau 

percent

Under 600 7 12 

600-649 3 12 

650-699 9 15 

700-749 17 20 

750-799 41 28 

800 plus 23 13 

With information derived from Fair Isaac historical records, we are also able to compare 

the distributions of credit scores in our sample with national distributions in 50-point 

intervals (Table 8). The implications are the same. The sample contains a greater 

proportion in the upper credit-score intervals and a smaller proportion in the lower creditscore intervals. The skewness in this pilot study is even more pronounced than in the 

first pilot study – except in the case of the weighted sampling in the second mailing from 

the Navy federal Credit Union and in the targeted recruitment from the VITA program. 

In those cases, where an explicit effort was made to increase representation of individuals 

with scores in the lower credit-score quintiles, the distributions of credit scores more 

closely approximated the national norms (see Table 9). Using data from past loan 

applications, a Navy Federal analyst constructed a statistical model (using binary decision 

trees) that predicted the credit score quintile in which the member would most likely fall. 

Twice as many individuals predicted to have credit scores in the lowest quintile were 
19

selected for that mailing than individuals predicted to fall in the highest quintile (while 

still having 40% of the addressees in these two groups). 

Table 9 – Distribution of Credit Scores from Weighted Mailing and Targeted Direct 

Recruitment 

Credit-Score Range Number 

(percent) 

In Navy Federal 

Weighted Sample

Number 

(percent) 

from VITA 

Program 

Under 610 2 

(6.5) 

5 

(55.6) 

610-689 3 

(17.7) 

1 

(11.1) 

690-749 3 

(17.7) 

1 

(11.1) 

750-789 4 

(23.5) 

2 

(22.2) 

790 plus 5 

(29.4) 

0 

(0) 

Past and current VITA participants were invited strictly as a convenience sample (i.e., 

with no further analysis that reflected other characteristics). 

As in the first pilot study, we found that individuals in good credit standing (high credit 

scores with correspondingly low probability of default on debt) were more inclined to 

register for the study than individuals with low credit scores. Achieving sufficient 

numbers (though not necessarily equal) numbers of individuals in each quintile will be 

important in the national study for estimating over-all error rates and consequences of 

errors. Generally, credit records with low credit scores have more entries with negative 

connotation and therefore greater risk of containing the items in their reports that tend to 

be challenged. 

The demographics of the sample revealed a reasonable distribution according to gender 

and age. The sample consisted of 56 women (43.8%) and 72 men (56.3%). Ages of 

participants were distributed with: 

• 4.7% under 25 years old 

• 13.3% between 25 and 34 

• 21.1% between 35 and 44 

• 21.9% between 45 and 54 

• 22.7% between 55 and 64 

• 15.6% over 65. 

Eighty-one percent (80.5%) reported their race as white; 12.5% as black; 2.3% as 

Hispanic; 0.8% Asian and 3.9% other. In the national study, some targeted outreach 
20

would be required to include a representative number of Hispanic participants. Sixty-six 

percent (66.1%) of participants were married; 2.4% lived with a partner; 16.5% were 

never married; 15.0% were divorced, separated, or widowed. 

Sixty-six percent (66.1%) were college graduates of those 33.1% had graduate degrees. 

32.8% were categorized as being in professional occupations; 14.4% in administrative or 

managerial jobs; 8.8% in the trades; 8.8% in sales; 8.0% in clerical; 6.4% disabled and 

20.8% retired. 

Of the 128 participants, 126 (98.4%) furnished a figure for household income. The 

responses were distributed as follows: 

• 6.4% with household income below $25K 

• 16.7% between $25K and $50K 

• 22.2% between $50K and $75K 

• 15.9% between $75K and $100K 

• 34.1% over $100K. 

Procedures would have to be employed in a national study to offset bias toward older and 

more affluent consumers. With the ZIP codes used in the mailing addresses, we have the 

ability to compare geo-demographic characteristics for participating versus 

nonparticipating households in the target population and could use sequential sampling 

techniques to increase participation in segments that are underrepresented as the sample 

evolves. Average real-estate valuations (and recent changes herein), mortgage 

delinquency rates, and credit-card delinquencies could be acquired from governmental 

agencies and financial institutions and used to construct a sampling frame. Outreach 

through social service agencies might also be needed to secure sufficient participation of 

individuals with lower credit scores and from groups with lower socio-economic status. 

One might speculate that requiring the consumer to use the internet to participate in the 

study may itself bias the sample toward more affluent segments of the population. The 

so-called digital divide between households with internet service and those without is 

gradually disappearing, as 73% of U.S. households are estimated now to have internet 

access (http://www.internetworldstats.com, October 15, 2008). Nevertheless, some 

representation of consumers without internet access may be desirable. 

Illustrative Findings from the Pilot Study 

In this section we provide some prototypical results to illustrate the information that 

would be garnered from a national study. Based on the intensive reviews of the credit 

reports, we produce a comprehensive summary of the results of the each consumer’s 

review of the accuracy of items in his or her credit reports. Specifically, we note 

whether there is an allegation of a significant inaccuracy (other than inconsequential 

typographical errors) involving: 

• an incorrect current address 

• an error in previous addresses (listing an address with which the person had no 

prior affiliation) 
21

• an error in employment history (citing an employer for whom the person had not 

worked) 

• an alleged reporting of invalid accounts (accounts that were claimed not to 

belong to the participant or cosigned by the participant) 

• a reporting of an allegedly incorrect balance on an account (a balance beyond the 

limits that could have been reached at any time in the reporting period) 

• a reporting of inquiries for credit that were allegedly not initiated by the 

consumer 

• a reporting of negative items (late payments) that allegedly had not occurred 

• an alleged error in the total number of accounts that could have had nonzero 

balances at any time in the reporting period 

• an alleged error in the number of public derogatories (e.g., bankruptcies) 

• accounts submitted for collection and current balances thereon 

• an alleged error in the individual bureau’s measure of revolving credit utilization 

that could not be explained by differential treatment of home equity loans. 

Recall that we employ a further screen to determine whether an alleged error could 

potentially affect an individual’s credit score by a material amount. If the case involves a 

potentially material error, we expose the account to rescoring of the frozen file, help the 

consumer engage in the dispute process, and draw a later credit report to determine the 

outcome. Recall that an alleged error was classified as potentially material if the credit 

score from the bureau was less than 760 (the cutoff for classifying a consumer as having 

very low credit risk) and the review of the credit report uncovered: 

• an alleged error in number of negative items (such as late payments), or 

• an alleged inaccurate number of public derogatories, or 

• an alleged error in number of accounts sent to collection, or 

• an alleged error in number of inquiries for new credit (hard pulls on the file), or 

• an alleged error in outstanding balances not attributable to normal monthly 

reporting variation, or 

• an allegation of accounts on the report not belonging to the client, or 

• duplicate entries of the same information (such as late payments or outstanding 

obligations) that were double-counted in reported summaries of such items. 

In Table 10, we summarize the outcomes from the review of the credit reports for 

participants in the different credit-score quintiles. Over all, 11.7% of participants (15 of 

128) alleged that there was at least one error that met our materiality criterion in one of 

their three bureau reports. As expected, the percentage of consumers having allegations 

of material errors is higher among those with low credit scores than among those with 

high credit scores (dropping from 50.0% among those with an average credit score below 

610 to zero among those with an average credit score over 790. 

 
22

Table 10 – Allegations of Errors according to Credit Score Groupings 

Credit Score 

Category 

Total 

Number 

Of 

Completed 

Cases 

In Study 

Cases with 

No Alleged

Errors 

Cases with 

No Alleged 

Error 

in Material 

Category 

Cases with 

At Least 

One Alleged

Error in the 

Material 

Category 

Percent of 

Cases with at 

Least One 

Alleged Error 

in the 

Material 

Category 

Under 610 10 4 5 5 50.0 

610-689 12 8 8 4 33.3 

690-749 27 19 23 4 14.8 

750-789 35 26 33 2 5.7 

790 plus 44 31 44 0 0 

Totals 128 88 113 15 11.7 

We present these statistics to illustrate the nature of the general relationship between 

credit score and tendency to allege that there are errors in the credit bureau data. The 

sample size is far too small to provide a reliable estimate of accuracy for the universe of 

credit reports. We must emphasize that a much larger and more representative 

sample would be required to estimate the percentage of consumers nationwide who 

would similarly dispute the accuracy of information in their credit files. 

At the time of preparation of this report, sufficient time had passed to draw a second 

credit report to determine the results of disputes in 12 of the 15 cases with alleged errors 

of potentially material magnitude. The outcomes for each of the 12 cases are presented in 

Table 11A and Table 11B. 

First, in Table 11A we indicate, for each case with an alleged inaccuracy that met the 

threshold of being potentially material (and therefore resulted in the filing of a dispute 

with subsequent follow-up): 

• the number of unique and potentially material errors in the comprehensive credit 

record (treating an alleged error that appears in more than one bureau file as a 

single error) 

• the total number of bureau disputes (treating an alleged error that occurs in three 

bureau files, for example, as three errors in the aggregate credit record) 

• the number of bureau disputes that were changed fully in consonance with the 

request of the consumer in his or her dispute letters 

• the number of bureau disputes for which a partial change was imposed that 

addressed the consumer’s concern expressed in the dispute letter 

• the number of bureau disputes for which no revision was imposed 

• the number of bureaus with which a dispute was filed for the consumer 
23

• the number of bureaus that made all the requested changes to the consumer’s 

credit record 

• the number of bureaus that made some changes that addressed the consumer’s 

concerns 

• the number of bureaus that made no changes to the credit record that addressed 

the consumer’s concerns. 

In Table 11B we illustrate the information available to enable a thorough analysis of the 

impact of ultimate revisions to the credit reports upon the consumer’s credit scores. 

Specifically, we record the credit scores derived from: 

1. each of the initial credit reports (frozen files) analyzed by the consumer with help 

from the research associates 

2. the new files pulled to determine the effects of revisions made to the files of the 

bureaus with whom the consumer filed disputes 

3. the frozen files rescored after imposing revisions that had been made by the credit 

bureaus in consonance with the requests of consumers in their dispute letters 

(involving a second rescoring for cases where only partial revisions were imposed 

by the bureau). 

In the last two columns of Table 11B, we illustrate two summary measures of the impact 

of changes made to the credit reports. The first measure is the resulting change in lowest 

bureau credit score. The second measure is the maximum change in credit score that 

occurred for the consumer where a bureau applied revisions to the credit file (partial or 

full) that addressed issues raised in the dispute letters. 

We provide these results for the individual cases to illustrate the information that, in a 

national study, would be accumulated to characterize the frequency of alleged errors for 

various population segments and the results of disputes filed to deal with them. In reports 

for a study with a nationally representative sample, statistics could be produced to reveal: 

• alleged error rates for major population segments 

o credit-score groupings 

o major demographic groups 

• results of disputes filed for alleged errors that met the chosen materiality threshold 

for the study 

o whether the new file contained revisions that were fully consonant with 

the consumer’s request for change, whether partial revisions were imposed 

that addressed the dispute, or whether no changes were imposed following 

the dispute 

o changes in credit scores 

 on files with disputes but no requested changes imposed to the 

record 

 on files with disputes and requested changes partially imposed on 

the record 

 on files with disputes and requested changes fully imposed on the 

record.
24

Table 11A – Dispute Summary for Each Case where a Dispute Was Filed re an Alleged Inaccuracy Class

Material 

Case 

Number 

of 

Potentially 

Material 

Errors 

Number 

of 

Bureau 

Disputes

Number 

of Fully 

Consonant

Revisions 

Number of 

Partially 

Consonant

Revisions 

Number 

Unchanged 

Number 

of 

Bureau 

Contacts 

Involved 

Number 

with All 

Changes 

Imposed 

Number 

with 

Partial 

Change 

FTCG47L 1 2 1 0 1 2 1 0 FTCE68J 2 2 0 0 2 2 0 0 FTC7L90 1 1 0 0 1 1 0 0 FTCGN72 2 4 1 0 3 3 0 1 FTCSXL4 2 2 2 0 0 1 1 0 FTC7X60 1 2 2 0 0 2 2 0 FTC0KD0 1 1 1 0 0 1 1 0 FTCFP8A 1 3 2 1 0 3 2 1 FTCID00 2 2 2 0 0 2 2 0 FTC8RH3 1 2 2 0 0 2 2 0 FTCJE9W 5 7 7 0 0 3 3 0 FTCUANS 2 4 4 0 0 3 3 0 

TOTAL 21 32 24 1 7 25 17 2 
25

Table 11B – Changes in Credit Scores Following Rescoring of Frozen CreditBureau Files for Each Case where a Dispute Was Filed re an Alleged Inaccuracy 

Classified as Potentially Material 

Case 

Initial 

Credit 

Score 

Bureau 

A 

Initial 

Credit 

Score 

Bureau 

B 

Initial 

Credit 

Score 

Bureau 

C 

Rescored 

Credit 

Score 

Bureau 

A 

Rescored 

Credit 

Score 

Bureau 

B 

Rescored 

Credit 

Score 

Bureau 

C 

Revision 

Imposed 

(Y=yes 

N=No 

P=Partiall) 

FTCG47L 752 666 654 N/A 745 753 P 

FTCE68J 760 780 728 802 N/A 728 N 

FTC7L90 737 706 701 N/A N/A 738 N 

FTCGN72 543 560 541 548 560 541 P 

FTCSXL4 492 477 453 N/A 477 N/A Y 

FTC7X60 723 734 792 785 785 N/A Y 

FTC0KD0 809 727 823 N/A 806 N/A Y 

FTCFP8A 680 668 655 727 668 665 P 

FTCID00 684 679 677 684 N/A 718 Y 

FTC8RH3 487 588 558 545 623 N/A Y 

FTCJE9W 493 511 530 496 511 530 Y 

FTCUANS 513 634 600 524 618 660 Y 

Additional perspective can be gained by examining the outcomes of the dispute process 

according to the type of alleged error for which consumers filed a dispute. In Table 12, 

we show how this information may be accumulated across the different cases for which 

disputes were filed. The types of alleged error could be examined in terms of: 

• their frequency of report 

• their frequency of correction 

• the average changes in consumer credit scores 

o on files with disputes but no requested changes imposed to the record 

o on files with disputes and requested changes partially imposed on the 

record 

o on files with disputes and requested changes fully imposed on the record. 

In the first pilot study (http://www.ftc.gov/reports/FACTACT/FACT_Act_Report_2006.pdf ) we 

described other types of information that similarly may be garnered from the data. We do 

not repeat the illustrations here, as the purpose of this second pilot was not to generate 

comparative statistics based on small samples; rather it was to test the impact of changes 

in recruitment method, in the form of support provided for filing disputes, and in the 

statistics collected to characterize the outcomes for cases in which disputes were filed. 
26

Table 12 – Outcomes of Disputes for Alleged Errors of Different Types 

Type of Alleged Error 

Number of 

Potentially 

Material 

Errors 

Number 

of Bureau 

Disputes 

Number of 

Full 

Corrections 

Number of 

Partial 

Corrections 

Incorrect Collection Account Reported 6 9 7 0 Incorrectly reported late payment 3 5 1 0 Incorrectly reported consumer finance account 1 1 0 0 Multiple report of account in bankruptcy 2 4 4 0 Multiple report of account with late payment 2 2 2 0 Paid account reported as delinquent 1 1 1 0 Current collection balance reported incorrectly 1 1 1 0 Closed account reported delinquent 1 3 2 1 Chapter 7 accounts reported delinquent 4 6 6 0 Totals 21 32 24 1 
27

Changes from Pilot 1 to Pilot 2 in Analyzing Cases with Alleged Errors 

A specific type of error may have a different impact on the credit score for one consumer 

than for another (or for a single consumer at different points in time), depending on other 

information in the respective credit files. A late payment, for example, may be quite old 

and therefore not affect the credit score significantly. Several late payments may be 

removed from a credit record without affecting the credit score significantly if there are 

many other late payments that remain in the file. In the first pilot study, the principal 

investigators and professionals at Fair Isaac used an intervening review of each file to 

characterize each case as likely or unlikely to experience a significant change in credit 

score and classified the errors as material or immaterial based on the circumstances of the 

case itself. 

In this pilot study, we used uniform criteria to categorize an alleged error according to 

whether it could potentially have a material impact on the credit score of any consumer. 

We prepared the dispute paperwork in all such instances and followed the consequences. 

The impact of changes to the credit files following disputes may be measured by the 

resulting changes in credit score attributable to changes in the credit files that address the 

consumers’ disputes. We can produce that information in two ways. First (and 

primarily), to eliminate the effects of other information that may have appeared in the 

credit report in the meantime (such as changes in credit utilization or appearance of a new 

negative item), we can generate new credit scores by rescoring the frozen files after 

revising them (a second time, if necessary) to reflect changes in the bureau records that 

address the consumers’ disputes. Recognizing that the impact of a change in credit score 

can depend on other information in the credit file, we can also compare the credit scores 

from the new credit reports drawn to determine whether the requested changes in a 

dispute were applied to the file, with the credit scores from the frozen credit reports that 

were reviewed by the consumer. 

Implications for the Conduct of the National Study 

The research methodology and procedures used in this pilot study were found to be 

suitable for a comprehensive investigation of the accuracy of credit-bureau information in 

a study of national scale. They enable thorough investigations of the integrity of creditbureau information, provide data for estimating the frequency and severity of errors in 

existing files, and provide useful information about the workings and efficacy of the 

dispute-resolution process. 

The study website created substantial efficiencies in recruitment over the direct mail 

approach used in the first pilot study. Referral of clients from financial institutions to the 

study website proved to be a highly effective channel that we would recommend for the 

national study. To generate a nationally representative sample (or sufficient numbers in a 

stratified sample for adjusting error rates to account for different response rates), it will 

be necessary, however, to employ mechanisms such as weighted random sampling and 
28

targeted outreach to engage sufficient numbers of individuals in population segments 

prone to low credit scores. 

In that regard, a limited test of a weighted selection mechanism when preparing a mailing 

to credit-union members produced a sample closer to national norms. Direct recruitment 

of individuals engaged in a nonprofit program for assistance in income-tax preparation 

also proved to be an effective tactic for engaging individuals with more challenging 

credit histories and lower credit scores. 

We recommend that the national study use multiple channels for referring potential 

participants to the study website including: 

• referrals from banks that ensure national geographical coverage 

• referrals from S&L’s that ensure national coverage 

• referrals from employers to their employees, with weight given to younger 

individuals and to persons in lower job categories to compensate for the greater 

tendency of higher-income individuals to participate 

• referrals using brochures or letters to clients of social service agencies to reach 

segments of the population that may have had difficulties in managing their credit 

• mechanisms to increase the representation of the Hispanic population and 

modification of the study website for use in Spanish. 

In addition, there should be direct recruitment of individuals through on-site visits to 

social service agencies (including voluntary income tax preparation programs) as a means 

of reaching segments of the population without personal internet access. A combination 

of weighted random sampling through the aforementioned referral channels and direct 

recruitment through social-service agencies would likely prove effective in generating a 

sufficiently representative sample. 

Additional involvement of the research associates in preparing dispute letters for cases 

with alleged inaccuracies in credit-bureau files dramatically increased participation in the 

dispute process and enabled a more thorough study of credit-bureau accuracy. We 

recommend that this type of support be offered in the national study. 

Planning Parameters for the National Study 

The national study will require representation with diverse demographic characteristics 

from all geographical regions (including urban and nonurban residents from each of the 

50 states). To achieve estimation precision of plus or minus three percent in over-all 

percentage statistics with 95% confidence, a total of 1000-1100 fully completed cases 

will be needed. We suggest the following guidelines for estimating the effort required to 

complete the national study (assuming a total sample of 1000 completed cases) is to be 

obtained). 

• Use a study website (as in Pilot 2 but with English and Spanish versions) with 

referrals from banks and S&L’s as the primary recruitment channel (for 550 

participants) 
29

• Use referrals to the study website from employers to ensure occupational diversity 

in the sampling frame ( for 250 participants) 

• Use referrals to the study website from VITA programs and social service 

agencies to reach the population segments with lower credit scores (for 50 

participants) 

• Recognizing the additional cost, use direct recruitment by mail and telephone only 

as needed to achieve the desired geographic and demographic representation (for 

50 participants) 

• Use direct (face-to-face) recruitment through from VITA programs and socialservice agencies to enroll participants who do not have internet access (for 50 

participants). 

 Effect of the Blend of Recruitment Channels on Study Costs 

The most efficient channel involves much less effort on the part of research associates for 

each completed case. The cost of the national study will depend on the extent of outreach 

required through the other channels. Based on our experience in the two pilot studies, we 

have produced estimates of the relative variable costs (primarily research associate time) 

that would be incurred for each completed case from the alternative recruiting channels. 

Considering the recruiting yields, the effort involved in recruitment, in scheduling (and 

re-scheduling) the comprehensive reviews, and the effort expended in the dispute 

process, we express the estimated costs as a multiple of those incurred in serving the 

referrals from financial institutions to the study website (the recommended primary 

recruiting channel). We include those relative cost estimates with other characteristics of 

the recruiting channels in Table 13. For example, note that we estimated the total costs 

of completing the process for individuals recruited by direct mail and telephone followup to be three times the total cost of completing the process for individuals referred by 

financial institutions to the study website (the primary channel). 

If the channels are used with our suggested mix, the cost of completing the study for 

1000 new participants would be equivalent to serving 550+250+3*50+3*50+5*50 = 

1350 individuals via referrals from financial institutions and employers to the study 

website alone. The implication of this is that the study costs would be increased by 

approximately 35% if our suggested mechanisms are used to engage segments of the 

population without internet access and hard-to-reach groups that are likely to have lower 

credit scores. 

We did not offer financial incentives to encourage participation and follow-through for 

study registrants; nor did the cooperating financial institutions charge for their expenses. 

If such incentives were to be offered to all or selected segments of the population, or to 

cooperating referring institutions and agencies, the fixed and variable costs for activities 

in the national study would consequently change. 
30

Table 13 - Recruiting Channel Characteristics and Workload Impact 

Recruiting 

Channel 

Variable 

Cost 

Ratio 

(Estimated) 

Administrative 

Overhead 

Geographical 

Representation 

Yield 

(participants 

per contact) 

Targeted 

Engagement

Potential 

Bank and 

S&L 

Referrals to 

Study 

Website 

1.0 Low High Low Med 

Employer 

referrals to 

website 

1.0 Med Med Potentially 

Medium 

Med 

VITA and 

Service 

Agency 

referrals to 

website 

3.0 Hi Low Low High 

Direct mail 

With 

Telephone 

Follow-up 

3.0 Med High Med Med 

In-Person 

Recruitment 

from Service 

Agencies 

5.0 High Low Med High 

Acknowledgements 

The investigators are grateful to executives and senior staff at Navy Federal Credit Union 

and Commerce Bank for their help in testing study protocols, and for offering a sample of 

their members and customers the opportunity to participate by referring them to the study 

website. The involvement of these institutions was integral to the success of this second 

pilot study and to the design of efficient procedures for use in the national study. 
i

Exhibit 1 – Solicitation and Referral Letters for Recruiting and 

Engaging Participants 
ii

Exhibit 1A

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Your household has been selected for possible participation in a study on the accuracy of credit 

reports. The Congress of the United States has directed the Federal Trade Commission (FTC) to 

perform this study. You may already know that the FTC is the nation=s consumer protection 

agency. If you wish to read more about the FTC and this directive from Congress, please visit the 

FTC=s web site (instructions given below). You will see that we are preparing a pilot study before 

we carry out a national study of credit reports. Your name was selected for the pilot study by a 

procedure designed to create a representative random sample for the study. 

As you know, accuracy in credit reporting is very important to consumers. The information in 

credit reports can be the key to getting or setting the terms of a mortgage, a loan, credit cards, 

insurance, and even a job. The purpose of the FTC=s study is to see if the information in credit 

reports is accurate. Participants will benefit from a careful review of their own credit files and 

from an opportunity to correct items that they believe to be in error. The study includes strict 

measures to protect the confidentiality of a consumer=s personal identifying information (more on 

this below). 

The FTC has retained researchers from the University of Missouri-St. Louis, who will also be 

working with researchers from George Washington University and the Fair Isaac Corporation, to 

execute this study. A representative will be calling by telephone soon to confirm whether a 

member of your household fits the study criteria. (Please wait for this call before deciding to 

return a consent form.) The researcher will ask some Ayes/no@ questions, such as whether a 

member of your household has had a credit card or loan from a financial institution. If you meet 

the criteria, a researcher will explain more fully what the study involves. 

In brief, participants receive credit reports and credit scores from the three major U.S. credit 

bureaus at no cost. They also receive free expert advice in understanding and reviewing their 

credit reports. For a cross-section of participants, researchers will conduct an in-depth telephone 

interview to help them identify possible inaccuracies. In cases where participants identify items 
iii

FEDERAL TRADE COMMISSION 

that seem to be wrong, the researchers guide the participants in filing formal disputes with the 

relevant parties and they track the results of the disputes to determine if corrections are applied to 

credit-bureau files. Participants thus benefit from a careful review of their own credit files and 

from an opportunity to correct items that they believe to be in error. Overall, the study will help 

American consumers and financial institutions by testing the accuracy of the credit reporting 

system.

This study is designed carefully to protect your privacy, and your participation is voluntary. 

Enclosed is a copy of a consent form that we require of all participants. Participants give the 

researcher written permission to arrange for delivery of the credit reports and to review them over 

the phone to help identify possible inaccuracies. You may be assured that we are collecting this 

information only for the purpose of this study and that the use of this information is protected and 

regulated by law. (See Privacy Act Statement below). 

If you would like to know more about this project or to verify the information in this request, 

please visit the FTC=s web site.* Thank you for considering this important matter. 

Sincerely, 

___________________________ 

Peter J. Vander Nat, Ph. D. 

FTC Coordinator for Pilot Study 

Pilot Study Approved by 

 Office of Management and Budget 

OMB Control No. 3084-0133 

Expiration: March 31, 2009

___________________________ 

* At www.ftc.gov/os/statutes/fcrajump.htm, click the link to: AFTC Announces Pilot Study and 

Requests Comments to Aid Accuracy Study.@ The comment period is no longer open; this site is 

now for reference.

Privacy Act Statement. As noted above, Congress has directed the FTC to do this study, and The 

Fair and Accurate Credit Transactions Act of 2003 permits the collection of information from you 

for the purpose of this study. The FTC’s researchers will be collecting this information, but the 

FTC does not intend to make any of your personal information part of its own records. To the 

extent that the Privacy Act of 1974 applies, your information would be treated as part of the 

agency's legal records system. You can read about routine uses of such records on the FTC's Web 

site at: http://www.ftc.gov/foia/sysnot/i-1.pdf or http://www.ftc.gov/foia/sysnot/i-1.wpd. 

Your participation is completely voluntary, but please understand that if you choose not to provide 

information that we need for the study, then you cannot qualify to be a participant in the study. 

 Page 2 
iv

Exhibit 1B 
v

Exhibit 1C 
vi

Exhibit 1D 

CENTER FOR BUSINESS & INDUSTRIAL STUDIES

L. Douglas Smith, Ph.D., Director College of Business Administration 

e-mail: ldsmith@umsl.edu One University Blvd. 

 St. Louis, MO 63121-4499 

 Telephone: (314)516-6108 

 Fax: (314)-516-6827 

TO: UMSL VITA CLIENTS 

We are pleased to announce an opportunity for clients in the UM-St. Louis Volunteer Income 

Tax Preparation Assistance program to benefit from another program of community service 

through the UM-St. Louis College of Business Administration. Under a Service Learning grant 

from State Farm Insurance, research associates of the Center for Business and Industrial Studies 

(CBIS) are offering, without cost, a valuable program of individual financial planning. The 

program has two major thrusts: 

1. An individual personal finance review that enables you to project your financial situation 

through retirement under different planning assumptions 

2. A credit audit that includes free credit reports and free credit scores from the three major 

U.S. credit bureaus. Part of the credit audit involves a thorough review of the creditbureau data to check it for accuracy. We offer that in conjunction with a university 

research project sponsored by the Federal Trade Commission (FTC). 

There is, of course, no obligation to participate in either of these programs. Both are offered free 

of charge. You may choose to participate in one, the other, or both. If you participate, your 

privacy will be completely protected. We believe that this is an excellent opportunity for an 

individual to undertake an important personal financial review, ensure the integrity of 

information stored in his or her credit-bureau records, arrange for the correction of any erroneous 

information, and possibly make changes that could reduce the costs of credit or insurance. 

To inquire about participation in this program, you may call the UMSL Center for Business and 

Industrial Studies at (314) 516-6169 or send an e-mail to busresc2@umsl.edu to indicate how 

and when a university associate might conveniently reach you by telephone. You may also visit 

“ftcstudy.umsl.edu” and enter “vita001” as the study code to learn more about the FTC study and 

register as a participant. 

Sincerely, 

L. Douglas Smith, Ph.D. 

Professor and Director 

College of Business Administration 

One University Blvd. 

St. Louis, MO 63121-4400 
vii

Exhibit 1E 

CENTER FOR BUSINESS & INDUSTRIAL STUDIES

L. Douglas Smith, Ph.D., Director College of Business Administration 

e-mail: ldsmith@umsl.edu One University Blvd. 

 St. Louis, MO 63121-4499 

 Telephone: (314)516-6108 

 Fax: (314)-516-6827 

Dear 

Enclosed you will find the credit reports that were available in your name from Equifax, Experian and 

TransUnion –the three major U.S. credit bureaus. Also enclosed is a checklist to help guide your 

review of the information they contain. 

In our telephone interview, we will ensure that you have thoroughly examined the information and 

identified any items that seem to be incorrect. Preparing for the interview with the checklist will help 

us be more efficient in the telephone review. 

You may keep in mind that account numbers sometimes change as a result of a card that is reported 

lost or stolen, or as organizational changes occur in financial institutions. In such cases, the data for a 

familiar credit card or bank account may appear under one number until the account was closed and 

under another number thereafter. 

The account balances shown will depend on the day of the month that the data were sent to the credit 

bureau and will vary according to the days that payments and charges were processed by the financial 

institution. You need not verify the specific account balances – just check to make sure that the 

balances shown could have occurred on one day during the relevant month. Also, not all creditors 

report to all bureaus and the credit scores are derived from the individual bureaus’ data. Thus, there 

will be some natural variation among the credit files and in the resulting credit scores. 

You may leave a message at 314-516-6169 or send an e-mail message to busresc2@umsl.edu to let us 

know the best time to call and the best telephone number to use for our review of your credit reports. 

Thank you again for your participation in this important study. We look forward to checking the 

reports’ accuracy with you as soon as possible. 

Sincerely, 

Chloé Gray-Le Coz Luigi Wewege 

Research Assistant to L. Douglas Smith Research Assistant to L. Douglas Smith 

University of Missouri - St. Louis University of Missouri - St. Louis 

Center for Business and Industrial Studies Center for Business and Industrial Studies 
viii

Exhibit 2 – Illustrations of Internet Website Screens for Providing Study 

Information, Issuing Reproducible Electronic Consent, and Registering 

Study Participants 
ix

Exhibit 2 – Website Used for Providing Study Information, Issuing 

Reproducible Electronic Consent, and Registering Study Participants 

I. For study information and registration, go to the study website address: 

http://ftcstudy.umsl.edu

II. The following web page will appear: 

To continue you type in the study code furnished to you by the university research 

associates or participating institutions. 
x

III. FTC Study Information 
xi

IV. Study steps. 

V. Confirmation that participant meets qualifying criteria. 
xii

VI. Provision of a reproducible electronic consent appears next. 
xiii

VII. Details of Electronic Consent Screen 

Consumer Consent for Participation in Pilot Study of Credit Report Accuracy

I am giving permission to the FTC’s designated researchers from the University of Missouri-St. Louis, 

George Washington University, and the Fair Isaac Corporation (“the research team”) to obtain copies of 

three respective credit reports and credit scores for me – one from each of the nationwide credit 

reporting agencies: Equifax, Experian, and TransUnion. 

The research team will review my credit report information with me to see if I believe there are 

inaccuracies, and I will receive advice on the difference between a small inaccuracy (such as a 

misspelling of my name or address or a date when an account was closed) and a potentially significant 

error (such as a missed payment or collection activity) that could affect my credit rating. The research 

team will explain how I may challenge information that I believe to be significantly in error, and the 

research team will follow the results of disputes with the credit reporting agencies. There is no 

monetary cost to me for obtaining my three credit reports, the related credit scores, or any assistance 

provided by the research team. 

I agree to provide the research team with information about the results of any disputes that I register 

with a credit bureau or lender as a result of the review of my credit reports. Upon the completion of any 

dispute process, I understand that a new credit report will be drawn to check the outcome of the dispute. 

I further understand that any information collected about me, whether credit report information or 

any information that I supplied as a participant in this study, is collected only for the purpose of 

the study described in the attached FTC letter. I 

understand that the use of this information is protected and regulated by law, and I have read the 

Privacy Act Statement. 

Privacy Act Statement. The Fair and Accurate Credit Transactions Act of 2003 permits the collection 

of information from you for the purpose of this study. The FTC's researchers will be collecting this 

information, but the FTC does not intend to make any of your personal information part of its own 

records. To the extent that the Privacy Act of 1974 applies, your information would be treated as part of 

the agency's legal records system. You can read about routine uses of such records on the FTC's Web 

site at: http://www.ftc.gov/foia/sysnot/i-1.pdf or http://www.ftc.gov/foia/sysnot/i-1.wpd. 
xiv

VIII. Version of the Consent Form Presented for Printing and Mailing: 
xv

IX. Screen for Personal information. 
xvi

X. Screen Confirmation and E-Mail Sent with Confirmation of Purchase Voucher Number 

and Logon Information for Fair Isaac 
xvii

XI. Fair Isaac Portal 
xviii

 Creating the myFICO account. 
xix

XII. MyFICO User Agreement 

 
xx

XIII. myFICO.com requires participants to answer two simple questions to prove their 

identity and authenticate their account. 
xxi

Exhibit 3 – Checklist for Consumer to Prepare for In-Depth Review 

of Credit Reports 

Checklist for Reviewing Your Credit Files

To assist you in reviewing your credit bureau files, we suggest you proceed as follows: 

1. As you examine the credit bureau reports, please note that each credit agency has a slightly 

different format for reporting the same basic information. Along with the reports, you should 

have received some instructions provided by the credit bureaus that are designed to help you 

understand the various items shown in your report. 

2. We suggest you start with just one report and conduct a complete review of it before looking 

at the other reports. It would be most helpful when we call to interview you if you focus on these 

areas: 

* Is your name, address, and other identifying information in the front of the report 

correct? 

* If you currently have a mortgage on a home, is the name of the lender, outstanding 

balance, date opened, number of delinquencies, etc. correct? 

* If you have had any car loans in the last 7 years, try to find those in the report paying 

special attention to the date of loan, lender name, loan balance and payment history. Are 

they correctly reported? 

* For every credit card you currently have, locate it in the report and check the date 

issued, lender name, current balance and payment delinquencies (if any). Are all of these 

items correct? 

* If you currently have other types monthly installment loans for purchasing goods or 

services, please locate those in the report. Pay special attention to the date of loan, lender 

name, current balance and payment delinquencies (if any). Are all of these items correct? 

* For any closed loans (mortgages, car loans, credit cards, etc.), carefully exam those for 

which the report suggests there may have been some delinquent payments. Does this 

information appear correct? 

*Does the report show any loans that went to collection? Is the information reported 

correct? (Collection means you were in default on the payments and the lender hired a 

collection agency to try to collect the money from you.) 

3. After you have reviewed one report in detail, do the same thing for the other credit bureau 

reports. Do you see any significant differences between the reports? What are they? 
xxii

Exhibit 4 – Sample Spreadsheet used in Preparing for the Review (with CrossBureau Comparisons of Key Information in Credit Reports) 
xxiii

Particulars (FTC05AE) Trans Union Equifax Experian 

 

FICO Score: 753 792 766 

Name: Suppressed Suppressed Suppressed 

SSN: (digits suppressed by bureau) Not shown Not shown Not shown 

DOB: Suppressed Suppressed Suppressed 

Current Address: Suppressed Suppressed Suppressed 

Previous Addresses: Suppressed Suppressed Suppressed 

Employment History: Suppressed Suppressed Suppressed 

 

No. of Accounts: 48 35 48 

No. of Accounts with Balances: 10 10 10 

No. of Accounts that are Negative: 0 0 0 

No. of Credit Inquries for Applying for 

Credit: 5 0 1 

Length of Credit History: 20, 10 20, 10 20, 00 

Date of First Loan: Sep-87 Sep-87 Sep-87 

No. of Loan/Credit Cards opened Last 

Year: 3 3 3 

Latest opened Loan/Credit Card: Mar-08 Mar-08 Mar-08 

 

All Accounts: 14 14 14 

Amount of Avaliable Credit ($): $290,618 $290,618 $271,504 

Amount of Balances ($): $208,951 $208,777 $208,777 

Credit Utilization (%): 72% 72% 77% 

 

Credit Cards / Charge Accounts: 

No. of Credit Cards: 8 8 8 

Date of First Credit Card opened: Sep-94 Sep-94 Sep-94 

Amount of Avaliable Credit ($): $71,656 $71,656 $71,656 

Amount of Balances: $8,929 $8,929 $8,929 

Credit Utilization (%): 12% 12% 12% 

 

Revolving Accounts (HEL, LOC, CC, 

ODRC): 8 8 8 

Amount of Available Credit ($): $71,656 $71,656 $71,656 

Amount of Balances ($): $8,929 $8,929 $8,929 

Credit Utilization (%): 12% 12% 12% 
xxiv

 

Instalment Accounts: 6 6 6 

Mortgage and Home Equity Loans: 2 2 2 

Total Mortgage: $151,200 $151,200 N/A 

Mortgage Balance: $139,997 $139,997 $139,997 

Total Available Credit Home Equity 

Loans: $0 $0 $0 

Balance of Home Equity Loans: $0 $0 $0 

Total Balance ($): $139,997 $139,997 $139,997 

 

Other (Automobile, Business, Student 

Loans): 4 4 4 

Total Balance ($): $60,025 $59,851 $59,851 

 

Total Balance less Mortgage and HEL 

($): $68,954 $68,780 $68,780 

Negative Items: 1 0 1 

Derogatory Public Records: 0 $0 0 

Original Amount Due: 0 0 0 

Current Amount Due: 0 0 0 

Collections: 0 0 0 

Original amount due: $0 $0 $0 

Current Amount Due: $0 $0 $0 

No. of Delinquency (30 days past due): 1 0 1 

No. of Delinquency (60+ days past 

due): 0 0 0 

No. of Current Delinquency (30 days 

past due): 0 0 0 

Date of Delinquencies: July-03 N/A July-03 

Amount of Current Past Due ($): $0.00 $0.00 $0.00 

Delinquency Rate (%): 2% 2% 2% 

Name / ID : ------- 

Start Time: End Time: 
xxv

Exhibit 5 – Interviewing Guide for In-Depth Review of Credit 

Reports 
xxvi

Interviewing Guide for In-Depth Review of Credit Reports 

Introduction 

This is [name] calling from the University of Missouri-St. Louis regarding the FTC study on the 

accuracy of credit bureau information. 

May we review your reports with you now? 

The process that we use is first to answer any questions that you may have about the content of the 

credit reports. Then we discuss any possible inaccuracies that you may have identified in your own 

review. Next, we’ll discuss the findings from our comparison of the information in the three bureau 

reports. Finally, I will ask you for some general demographic information. 

Review of Credit Reports 

Using the check list that we provide in the packet containing your credit reports, did you find any 

questionable items? 

If no, confirm that they have covered each category in the checklist. (The check list outlines each 

item that the participant should review prior to the interview. Mention each item in the check list.) 

If yes, what did you find? 

Obtain clarification for each issue or alleged error, starting with the disputed credit report and 

comparing the corresponding information in the other credit reports. 

When all the consumer’s questions have been answered, address any inconsistencies or irregularities 

identified in the preparatory review of the credit bureau data. 

From our own review, we have a few questions that we would like to address. 

(If there are any derogatory items, review these with the participant to insure that the facts are 

correctly presented.) 

If the consumer affirms that the records are accurate, complete the closing survey with demographic 

questions and express thanks for participation. 

Discuss any alleged discrepancies and identify those that could be potentially material. Obtain 

clarifying information for filing disputes if warranted. 

Dispute Process 

Describe the content of any dispute letter that will be prepared for the consumer. Explain that the 

letters will be mailed to the consumer for review, addition of Social Security number, and mailing to 

the appropriate bureau(s). Also ask the consumer to return the accompanying postcard verifying that 

the letters were mailed. Request that the participant forward any correspondence received from a 

credit bureau or creditor in response to the dispute letters. For potentially material disputes, explain 

that the research team will draw a new credit report in about 8 weeks to see what changes are made 

in response. 
xxvii

Background Information for Addressing Common Questions 

Collection accounts: 7 years from the date of the initial missed payment that led to the collection (the 

original delinquency date). When a collection account is paid in full, it will be marked "paid 

collection" on the credit report. 

Charged-off accounts: 7 years from the date of the initial missed payment that led to the charge off 

(the original delinquency date), even if payments are later made on the charged-off account. 

Closed accounts: Closed accounts with delinquencies remain 7 years from the date they are reported 

closed, whether closed by the creditor or by the consumer. Positive closed accounts remain 10 years. 

Lost credit card: Will continue to be listed for 2 years from the date the card is reported lost. 

Delinquent payments that occurred before the card was lost are reported for 7 years. 

Bankruptcy: Chapters 7, 11, and 12 remain for 10 years from the filing date. Chapter 13 remains 7 

years from the filing date. Accounts included in bankruptcy will remain 7 years from the date they 

were reported as included in the bankruptcy. 

Child support judgments: 7 years from the date the judgment is filed. 

Civil and small claim judgments: 7 years from the date the judgment is filed. 

City, county, state, and federal tax liens: Unpaid tax liens remain 15 years from the filing date. Paid 

tax liens remain 7 years from the paid date of the lien. 

Inquiries: Most inquiries listed on your credit report will remain for 2 years. 

 

Positive open credit information remains indefinitely and paid positive accounts remain 10 years.
xxviii

Exhibit 6 – Sample Letters Prepared for Consumer to Facilitate Filing a 

Dispute 
xxix

CENTER FOR BUSINESS & INDUSTRIAL STUDIES

L. Douglas Smith, Ph.D., Director College of Business Administration 

e-mail: ldsmith@umsl.edu One University Blvd. 

 St. Louis, MO 63121-4499 

 Telephone: (314)516-6108 

 Fax: (314)-516-6827 

Dear 

Thank you for your participation in the University of Missouri— St. Louis’s joint project with the 

Federal Trade Commission. We have enclosed materials to assist you in filling dispute(s) with the 

relevant bureau(s) to resolve error(s) that you identified in our review. 

This package contains the following: 

 --2 dispute letters for each bureau involved, one to be sent to the appropriate credit and 

 bureau and one for your records. Please do not forget to sign this copy and enter 

the last four digits of your Social Security number. 

NOTE: If you are filling a dispute with Experian you must send a copy of a government issued ID 

(this includes driver license, Social Security card, passport, or State ID card.) 

 

 --Please mail the post card to the University after you have sent your dispute letter. You 

 can also e-mail busresc2@umsl to let us know that you have sent the letters. 

Again, thank you for your participation and please call 314-516-6169 or e-mail busresc2@umsl.edu 

with any questions or concerns. 

Chloé Gray-Le Coz Luigi Wewege 

Research Assistant to L. Douglas Smith Research Assistant to L. Douglas Smith 

University of Missouri - St. Louis University of Missouri - St. Louis 

Center for Business and Industrial Studies Center for Business and Industrial Studies 
xxx

Exhibit 6A 

Do Not Mail This Page 

Instructions for mailing your letter: 

Following this cover sheet, you'll find your personalized dispute letter. 

Be sure to do the following: 

1. Sign your letter (signature line is at the end of the letter.) 

2. Fill in the last four digits of your Social Security Number (at the end of the letter.) 

3. Also, if available, include any documents you have that will support your case. 

4. Mail the letter (along with any additional documents) to the credit bureau. 

5. Be sure to keep copies for your records. 

Completing these steps will begin the dispute process. You should receive a response from the credit bureau 

within 30 days. 

TransUnion Consumer Solutions 

P.O. Box 2000 

Chester, PA 19022-2000 

Quick tip 

Some browsers automatically include header and footer lines when you print a page. Removing these is easy. In 

Internet Explorer, select the "File" menu and choose "Page Setup". The page setup dialog box will open. Simply 

delete the text found inside the "Header" and "Footer" text boxes (Save this text in a safe place if you wish to 

redisplay the header and footer in the future.) Then click the "OK" button. When you print your letter again, the 

header and footer will no longer be shown. Please note, these changes will affect all pages you print from any 

website. 
xxxi

Name 

Address 

City, State Zip 

Date 

TransUnion Consumer Solutions 

P.O. Box 2000 

Chester, PA 19022-2000 

To Whom It May Concern: 

After closely examining my TransUnion Credit Report obtained on mm/dd/yy, I have discovered the following 

errors: 

Problem 1 

The following account is listed on my report: 

Commerce Bank 

Account number: XXXXXXXXXXXX 

Date opened: 5/2002 

However, I have never opened this account. It is not my account and it should be removed. 

Problem 2 

The following account is listed multiple times on my report: 

Aes/Mohela 

Account number: XXXXXXXXXXXXX0001 

Date opened: 8/2006 

Description: Payment deferred 

Please list this account only once. 

I would appreciate your prompt response to these issues. 

Sincerely, 

___________________________________ 

(your signature) 

Name 

Address 

City, State Zip 

Date of birth:__________________ 

SSN:__________________ 
xxxii

Exhibit 6B 

Do Not Mail This Page 

Instructions for mailing your letter: 

Following this cover sheet, you'll find your personalized dispute letter. 

Be sure to do the following: 

1. Sign your letter (signature line is at the end of the letter.) 

2. Fill in the last four digits of your Social Security Number (at the end of the letter.) 

3. Also, if available, include any documents you have that will support your case. 

4. Mail the letter (along with any additional documents) to the credit bureau. 

5. Be sure to keep copies for your records. 

Completing these steps will begin the dispute process. You should receive a response from the credit bureau 

within 30 days. 

Equifax Information Services LLC 

P.O. Box 740256 

Atlanta, GA 30374 

Quick tip 

Some browsers automatically include header and footer lines when you print a page. Removing these is easy. In 

Internet Explorer, select the "File" menu and choose "Page Setup". The page setup dialog box will open. Simply 

delete the text found inside the "Header" and "Footer" text boxes (Save this text in a safe place if you wish to 

redisplay the header and footer in the future.) Then click the "OK" button. When you print your letter again, the 

header and footer will no longer be shown. Please note, these changes will affect all pages you print from any 

website. 
xxxiii

Name 

Address 

City, State Zip 

Date 

Equifax Information Services LLC 

P.O. Box 740256 

Atlanta, GA 30374 

To Whom It May Concern: 

After closely examining my Equifax Credit Report obtained on mm/dd/yy, I have discovered the following errors: 

Problem 1 

The following account is listed on my report: 

Bk Of Amer 

Date opened: 11/2007 

Description: Credit Card 

However, I have never opened this account. It is not my account and it should be removed. 

Problem 2 

An account on my report has an incorrect balance. The account is: 

Fst Comm 

Account number: XXXXXXX7001 

Date opened: 11/2007 

Description: Auto 

The balance is incorrectly reported as $12,209 but it should be: $2965. 

I would appreciate your prompt response to these issues. 

Sincerely, 

______________________________________ 

(your signature) 

Name 

Address 

City, State Zip 

Date of birth:__________________ 

SSN:__________________ 
xxxiv

Exhibit 6C 

Name 

Address 

City, State Zip 

Date 

Experian Dispute Resolutions 

P.O. Box 9701 

Allen, TX 75013 

To Whom It May Concern: 

After closely examining my Experian Credit Report obtained mm/dd/yy, I have discovered the following errors: 

Problem 1

The following account is listed on my report: 

Bk Of Amer 

Date opened: 11/2007 

Description: Credit Card 

However, I have never opened this account. It is not my account and it should be removed. 

Problem 2

An account on my report has an incorrect balance. The account is: 

Fst Comm 

Account number: XXXXXXX7001 

Date opened: 11/2007 

Description: Auto 

The balance is incorrectly reported as $12,209 but it should be: $2965. 

I would appreciate your prompt response to these issues. 

Sincerely, 

_______________________________ 

(your signature) 

Name 

Address 

City, State Zip 

Date of birth: mm/dd/yyyy 

SSN: ________________ 
xxxv

Exhibit 6D 

CENTER FOR BUSINESS & 

INDUSTRIALSTUDIES

L. Douglas Smith, Ph.D., Director 

College of Business Administration 

One University Blvd. 

St. Louis, MO 63121-4499

FTC ID:________________ 

I, , confirm that I have 

mailed dispute letters to the following credit bureaus: 

 Trans Union 

 Equifax 

 Experian 

On (date)________________________ 
xxxvi

Exhibit 7 – Follow-up Survey to Assess 

 the Process, Obtain Demographic Data and Confirm Dispute Outcomes 
xxxvii

Follow-up Survey for FTC Pilot

Mr (or Mrs) _________________, 

I am calling as a follow up to your participation in the FTC pilot study on the accuracy of 

credit-bureau data. We would like to include an assessment of the process as part of our 

report to the FTC and wonder if you would kindly answer a few short questions. 

1. Were you generally satisfied with the process we used to help you review your 

credit reports? 

2. Do you recall identifying any inaccuracies? 

3. Did you register a dispute with a credit bureau or creditor? 

(if yes, were you satisfied with the response?) 

4. About how much time do you recall spending to prepare for the review? 

Were the check lists helpful? 

5. About how much time do you recall the interview took to complete? 

6. Was the review thorough enough? 

(If no, ask what should have been done better.) 

7. Do you have any suggestions about how the study could be improved? 

 administer the demographic questionnaire if data are missing. 

To help us determine how representative our sample is, would you mind giving us some 

general information about yourself? 
xxxviii

Demographic Information: 

To help us classify your responses and to ensure that we work with a representative sample of 

consumers, we need a few items of personal information. 

Are you: 

under 25 __, 25-34___ ,35-44___ ,45-54___, 55-65___, 

over 65__ 

Would you classify yourself as 

White ___ Black ____ Hispanic ___ Asian ___ or Other ___? 

 

Are you: 

Married ___ , Living with a partner___, Never married___, Divorced ___ Separated ____ or Widowed 

___? 

Is your highest level of education 

No high school diploma___, some college___, bachelors degree___, graduate degree ___ 

What is your occupation? _____________ 

Are you: 

Employed by someone___, self-employed___,homemaker___, retired___, unemployed___, 

 disabled___, other___ 

If employed: 

Job title? _________________________ 

How many years have you been with your current employer? 

Is your total household income 

 _____ Under 25,000 

_____ 25,000 - 49,999 

_____ 50,000- 74,999 

_____ 75,000- 99,999 

_____ over 100,000 

 _____ refused to answer 

Do your own____, or rent____ your living quarters? 

Are there any children under the age of 18 living in the household? 

If yes, how many 
xxxix

Exhibit 8 – Offer of Expedited Review for Participants with Clean Credit History 
xl
xli

Exhibit 9 – Questionnaire for Expedited Review 
xlii

Confirmation of the Accuracy of Credit Bureau Data

This is to confirm that I have used the checklist provided for the FTC study on credit bureau accuracy 

and found no errors in the credit reports that were mailed to me. 

_____________________ ___________________ 

(Signature) (Date) 

To help us determine how representative our sample is, please complete the following general 

information. 

1. About how much time did you spent reviewing your reports? 

2. Was the check list helpful? Y_____ N_____ 

Are you: Under 25 __, 25-34___ , 35-44___ , 45-54___, 55-65___, over 65___ 

Would you classify yourself as: White ____ Black ____ Hispanic ____ Asian ____ or Other ___? 

 

Are you: Married ____, Living with a partner___, Never married___, Divorced ___ , Separated ___, 

or Widowed ___? 

Is your highest level of education: 

No high school diploma___, some college___, bachelors degree___, or graduate degree ___ 

What is your occupation? _____________ 

Are you: Employed by someone___, self-employed___, homemaker___, retired___, unemployed___, 

disabled___, other___ 

Is your total household income 

_____ Under 25,000 

_____ 25,000 - 49,999 

_____ 50,000- 74,999 

_____ 75,000- 99,999 

_____ over 100,000 

_____ refused to answer 

Do your own____, or rent____ your living quarters? 

Are there any children under the age of 18 living in the household? 

If yes, how many 
xliii

Exhibit 10 – Contents of SAS Database Created to Summarize Credit-Bureau 

Information and Outcomes for Each Participant 
xliv

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Data Set Name WORK.SURVEY Observations 120  Member Type DATA Variables 162  Engine V9 Indexes 0  Created Sunday, September 21, 2008 12:22:15 PM Observation Length 120 Last Modified Sunday, September 21, 2008 12:22:15 PM Deleted Observations 0  Protection Compressed NO  Data Set Type Sorted NO  Label  Data Representation HP_UX_64, RS_6000_AIX_64, SOLARIS_64, HP_IA64  Encoding latin1 Western (ISO)  Engine/Host Dependent Information  Data Set Page Size 65536  Number of Data Set Pages 3  First Data Page 1  Max Obs per Page 54  Obs in First Data Page 32  Number of Data Set Repairs 0  File Name /accounts/research/saswork/SAS_work093000003328_jinx/survey.sas7bda Release Created 9.0101M3  Host Created SunOS  Inode Number 57311751  Access Permission rw-r--r--  Owner Name cbis2  File Size (bytes) 204800  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  103 agejan1 Num 8  65 amtcollerr Num 8 amt. error/in coll./reported 
xlv

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  48 amtmtgebalerr Num 8 amt. error/in mtge.bal.  56 amtrevbalerr Num 8 amt. error/rev. credit/balance  117 avscore Num 8 average/credit/score  90 bureauchangeA Char 1 correction/made/Bureau A  91 bureauchangeB Char 1 correction/made/Bureau B  92 bureauchangeC Char 1 correction/made/Bureau C  1 case Num 8 sequence/number/for case  160 changeminscore1 Num 8 Change in/Min. Score/if File/Correc 161 changeminscore2 Num 8 Change in/Min. Score/Any Outcome  2 channel Char 8 $7. 7. Channel  81 checklisthelp Char 1 found/checklist/helpful  61 collamtA Num 8 amt. sent/to coll./Bureau A  62 collamtB Num 8 amt. sent/to coll./Bureau B  63 collamtC Num 8 amt. sent/to coll./Bureau C  66 collbalA Num 8 bal. on/coll./Bureau A  67 collbalB Num 8 bal. on/coll./Bureau B  68 collbalC Num 8 bal. on/coll./Bureau C  64 collecterr Char 1 error in/amt. sent/to coll.  44 curmtgbalA Num 8 total/mtge. bal./Bureau A  45 curmtgbalB Num 8 total/mtge. bal./Bureau B  46 curmtgbalC Num 8 total/mtge. bal./Bureau C  11 curraddOK Char 1 current/address/OK  112 curradderr Char 1 error in/current/address  7 dateofbirth Char 8 date of/birth  87 disputeA Char 1 disputed/item/Bureau A  88 disputeB Char 1 disputed/item/Bureau B  89 disputeC Char 1 disputed/item/Bureau C  93 disputecomment Char 40 dispute/info  94 disputefiled Char 1 dispute/filed  95 disputevalidated Char 1 dispute/validated  71 educlevel Char 1 educ/category 
xlvi

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  114 employhisterr Char 1 error in/employment/history  13 employhistok Char 1 employment/history/OK  73 employstatus Char 1 employ./category *  86 errtext Char 147 descriptive/summary  96 filescorrected Char 1 files/corrected  6 gender Char 1 Participant/Gender  38 histyymmA Num 8 credit/hist. yymm/Bureau A  39 histyymmB Num 8 credit/hist. yymm/Bureau B  40 histyymmC Num 8 credit/hist. yymm/Bureau C  75 homeeowner Char 1 owns/home  115 i Num 8  3 id Char 7 $7. 7. subject/id  74 incomegroup Char 1 income/group  34 inquiriesA Num 8 inquiries for/new credit/Bureau A  35 inquiriesB Num 8 inquiries for/new credit/Bureau B  36 inquiriesC Num 8 inquiries for/new credit/Bureau C  37 inquirieserr Char 1 wrong/credit/inquiries/  82 intervmins Num 8 mins./spent in/tel. review  76 kidsunder18 Num 8 no. children/under 18  159 mainchannel Char 24  70 maritalstatus Char 1 marital/cateegory  84 materialerr Char 1 errors/judged/material  157 maxcollamt Num 8 maximum/coll credit/amt  154 maxcollbal Num 8 maximum/coll credit/bal  150 maxcurmtgebal Num 8 maximum/mortgage/bal  162 maximprove Num 8 Maximum/Score/Improvement/After/Cor 140 maxmtgeamt Num 8 Maximum/Mortgage/Amount/Shown  134 maxnegitems Num 8 Maximum/No. Neg/Items/Shown  131 maxnonzerobal Num 8 max no./nonzero bal/accounts  137 maxpubderog Num 8 max no./pub derogs  147 maxrevbal Num 8 maximum/rev credit/bal 
xlvii

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  144 maxrevlim Num 8 maximum/rev credit/limit  109 maxrevutil Num 8 max pct/rev credit/utiliz  118 maxscore Num 8 maximum/credit/score  128 maxtotbal Num 8 maximum/tot credit/bal  124 maxyrshist Num 8 max years/credit/history  156 mincollamt Num 8 minimun/coll credit/amt  153 mincollbal Num 8 minimun/coll credit/bal  149 mincurmtgebal Num 8 minimum/mortgage/bal  139 minmtgeamt Num 8 Minimum/Mortgage/Amount/Shown  133 minnegitems Num 8 Minimum/No. Neg/Items/Shown  130 minnonzerobal Num 8 min no./nonzero bal/accounts  136 minpubderog Num 8 min no./pub derogs  146 minrevbal Num 8 minimun/rev credit/bal  143 minrevlim Num 8 minimun/rev credit/limit  110 minrevutil Num 8 min pct/rev credit/utiliz  119 minscore Num 8 minimum/credit/score  127 mintotbal Num 8 minimun/tot credit/bal  125 minyrshist Num 8 min years/credit/history  47 mtgebalerr Char 1 error in/mtge.bal.  41 mxmtgeA Num 8 total/mtge. amt./Bureau A  42 mxmtgeB Num 8 total/mtge. amt./Bureau B  43 mxmtgeC Num 8 total/mtge. amt./Bureau C  22 negitemsA Num 8 negative/items/Bureau A  23 negitemsB Num 8 negative/items/Bureau B  24 negitemsC Num 8 negative/items/Bureau C  25 negitemserr Char 1 error in/no. of neg/items  100 newscoreA Num 8 Updated/credit/score A  101 newscoreB Num 8 Updated/credit/score B  102 newscoreC Num 8 Updated/credit/score C  21 nonzeroerr Char 1 error in/nonzero/balances  104 nscores Num 8 no. of/scores/avail. 
xlviii

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  14 numaccA Num 8 active/accounts/Bureau A  15 numaccB Num 8 active/accounts/Bureau B  16 numaccC Num 8 active/accounts/Bureau C  17 numaccerr Char 1 invalid/account(s)/reported  142 numbureaudisp Num 8 No of/Bureaus/with/Disputes  58 numcollA Num 8 no. of/coll. actions/Bureau A  59 numcollB Num 8 no. of/coll. actions/Bureau B  60 numcollC Num 8 no. of/coll. actions/bureau C  116 numerrs Num 8 no. of/alleged/errors  18 numnonzeroA Num 8 nonzero/balances/Bureau A  19 numnonzeroB Num 8 nonzero/balances/Bureau B  20 numnonzeroC Num 8 nonzero/balances/Bureau C  105 numtyperr Num 8 Number/of Types/of Error  72 occup Char 1 occup/category  85 plandispute Char 1 plans to/register/dispute  80 prepmins Num 8 mins./spent/preparing  12 prevaddOK Char 1 previous/addresses/OK  113 prevadderr Char 1 error in/previous/addresses  26 pubderogA Num 8 no. of/public derogs./Bureau A  27 pubderogB Num 8 no. of/public derogs./Bureau B  28 pubderogC Num 8 no. of/public derogs./Bureau C  29 pubderogerr Char 1 error in/no. of/public derogs.  69 race Char 1 race cat.  158 rangecollamt Num 8 range in/coll credit/amt  155 rangecollbal Num 8 range in/coll credit/bal  151 rangecurmtgebal Num 8 range in/mortgage/bal  141 rangemtgeamt Num 8 Range in/Reported/Mtge amt  135 rangenegitems Num 8 range/in no./neg items  132 rangenonzerobal Num 8 range in no./nonzero bal/accounts  138 rangepubderog Num 8 range/in no./pub derogs  148 rangerevbal Num 8 range in/rev credit/bal 
xlix

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  145 rangerevlim Num 8 range in/rev credit/limit  152 rangerevutil Num 8 range in/pct rev cr./utiliz  129 rangetotbal Num 8 range in/tot credit/bal  126 rangeyrshist Num 8 range(yrs)/credit/history  78 recallinaccuracies Char 1 recalls/signif./inacurracies  79 registereddispute Char 1 registered/dispute  97 rescoreA Num 8 Rescored/credit/score A  98 rescoreB Num 8 Rescored/credit/score B  99 rescoreC Num 8 Rescored/credit/score C  52 revbalA Num 8 rev. credit/balance/Bureau A  53 revbalB Num 8 rev. credit/balance/Bureau B  54 revbalC Num 8 rev. credit/balance/Bureau C  55 revbalerr Char 1 error in/rev. credit/balance  49 revlimA Num 8 rev. credit/limit/Bureau A  50 revlimB Num 8 rev. credit/limit/Bureau B  51 revlimC Num 8 rev. credit/limit/Bureau C  106 revutila Num 8 Revised/Revolving/Credit Util/Burea 107 revutilb Num 8 Revised/Revolving/Credit Util/Burea 108 revutilc Num 8 Revised/Revolving/Credit Util/Burea 57 revutilerr Char 1 error in/rev. credit/utiliz  111 revutilrange Num 8 Range in/Revised/Credit/Utiliz  77 satisfiedprocess Char 1 satisfied/with/review  8 scoreA Num 8 Bureau A/credit/score  9 scoreB Num 8 Bureau B/credit/score  10 scoreC Num 8 Bureau C/credit/score  120 scorerange Num 8 range in/credit/scores  4 state Char 2 State/where/Residence/Located  83 thoroughreview Char 1 found/review/thorough  30 totbalA Num 8 total acc./balances/Bureau A  31 totbalB Num 8 total acc./balances/Bureau B  32 totbalC Num 8 total acc./balances/Bureau C 
l

 Contents of SAS Database for FTC Pilot 2 (including Items Computed for Reports and Analysis)  12:22 Sunday,  The CONTENTS Procedure  Alphabetic List of Variables and Attributes  # Variable Type Len Format Informat Label  33 totbalerr Char 1 invalid/acc.balance/reported  121 yrshista Num 8 Years/Account/History/Bureau A  122 yrshistb Num 8 Years/Account/History/Bureau B  123 yrshistc Num 8 Years/Account/History/Bureau C  5 zipcode Char 5 ZIP/code