Processes for Determining Accuracy of Credit Bureau Information 

Pilot Study Performed for the Federal Trade Commission 

Under Contract FTC04H0173 

 By 

L. Douglas Smith, Ph.D. 

Edward C. Lawrence, Ph.D. 

Thomas H. Eyssell, Ph.D. 

Aarti Dinesh, B.A. 

Amanda Supriadi, B.A. 

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. 

Gregory Elliehaussen, Ph.D. 

The Credit Research Center 

McDonough School of Business 

Georgetown University 

3240 Prospect Street, NW, Suite 300 

Washington, DC 20007 

Tel: 202-625-1384 

Fax: 202-625-0104 

Jeffrey Feinstein, Ph.D. 

Fair Isaac Corporation 

200 Smith Ranch Road 

San Rafael, CA 94903 

Tel: (415) 492-5333 

Fax: (415) 492-5693 

September 12, 2006 
Processes for Determining Accuracy of Credit Bureau Information 

Executive Summary 

The purpose of this pilot study was to develop and test research protocols for a national 

study on the accuracy of credit-bureau information. Thirty consumers from 22 states 

(including Alaska) were engaged in thorough reviews of their credit reports and credit 

scores from the three major U.S. credit bureaus. Participants were informed about the 

dispute resolution process and, in cases where they registered formal disputes, the 

research team tracked the results. 

The study demonstrated that, with meticulous preparation on the part of research 

associates, consumers can be recruited and engaged effectively in lengthy telephone 

interviews to review the voluminous information in their credit reports and check it for 

accuracy. Consumers will cooperate with the researchers in tracking the results of 

disputes, but not all consumers who identify errors will file disputes without help. 

The research protocols employed in the pilot study allowed participants to be engaged 

without revealing their social security numbers or specific account numbers to the 

research team. Yet they enabled thorough investigations of the integrity of credit-bureau 

information, tests of the extent to which errors have a material effect on measures of 

creditworthiness (credit scores), and assessments of the dispute-resolution process. 

The pilot study produced survey instruments, organizational tools and analytical 

structures for the national study. It demonstrated the importance of facilitative 

mechanisms for obtaining signed consent and drawing credit repots, and highlighted the 

need for additional inquiry into why consumers who plan to file disputes often delay the 

process or fail to do so. In a national study of credit-bureau accuracy, facilitative 

mechanisms may be required to encourage the filing of disputes by individuals who 

would otherwise not take the time to do so, despite their allegations of errors that might 

materially affect their credit standing. 

 
Table of Contents 

Study Background and Purpose .... Page 1 

Previous Research .... Page 1 

Considerations in the Study Design .... Page 3 

Study Process .... Page 3 

 Recruitment .... Page 5 

 Mechanics of acquiring credit reports and scores .... Page 6 

 Preparing for the credit-report reviews .... Page 9 

 Conducting the reviews .... Page 10 

 Tracking disputes .... Page 11 

Assessment .... Page 11 

 

Characteristics of the Sample .... Page 12 

Illustrative Findings .... Page 13 

 Following Disputes .... Page 16 

 Information re Errors and Cross-Bureau Consistency .... Page 18 

 Effects of Errors on Measures of Creditworthiness .... Page 23 

Implications and Recommendations .... Page 27 

 Alternative Methods of Constructing the Sample .... Page 28 

 Phishing and Data Security .... Page 29 

 Effort and Costs of a National Study .... Page 30 

 Additional Recommendations .... Page 32 
List of Exhibits 

Exhibit 1 – FTC Solicitation Letter 

Exhibit 2 – Consumer Consent Form 

Exhibit 3 – Follow-up Letter Sent from the University for Recruitment 

Exhibit 4 – Screening Interview Guide with Demographic Questionnaire 

Exhibit 5 – Instructions for Establishing MYFICO Account 

Exhibit 6 - Checklist for Consumer to Prepare for In-Depth Review of 

Credit Reports 

Exhibit 7 – Sample Spreadsheet for Cross-Bureau Comparisons of Key 

Elements in the Credit Reports 

Exhibit 8 – Interviewing Guide for In-Depth Review of Credit Reports 

Exhibit 9 – Information Given to Consumers re Filing Disputes 

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

Exhibit 11 – Follow-up E-Letters to Re-engage Participants and 

Inquire if Disputes had been Filed 

Exhibit 12 – Follow-up Survey to Assess the Process and Confirm 

Dispute Outcomes 
Processes for Determining Accuracy of Credit Bureau Information 

Study Background and Purpose 

The purpose of this pilot study is to develop and test procedures for engaging consumers 

to determine the accuracy of information in credit reports furnished by the three major 

U.S. credit bureaus (Equifax, Experian and TransUnion) and for assessing the 

mechanisms in place for dealing with alleged errors in the files. The pilot study is 

intended to furnish the FTC with vital information for the design of a nationally 

representative study of credit report accuracy that would provide an unbiased assessment 

of (1) the prevalence and severity of errors in the three national credit report repositories, 

(2) the impact of those errors on consumers, and (3) the efficacy of the dispute resolution 

process under the Fair Credit Reporting Act. 

The pilot study itself involved the recruitment and engagement of 30 participants and 

retrieval of their credit reports and FICO credit scores. An in-depth review of the credit 

reports was conducted with the participants to identify discrepancies and inaccuracies. 

Participants were informed about the dispute resolution process. In cases where the 

participants registered disputes, the research team tracked the results. 

In this report we describe the recruitment process and mechanisms used to protect the 

consumers’ private information. We furnish instruments developed to manage the 

recruitment process, guide the review of credit reports and follow-up on disputes. We 

provide statistics on yield and attrition at each stage, and we provide anecdotal 

information that will help in the design of the national study. 

Motivating Research 

As background, we offer a brief summary of findings from preceding studies on the 

integrity of credit-bureau data. Staten and Cate (2003) provide an overview of the 

regulation and performance of the credit-reporting industry under the Fair Credit 

Reporting Act. Their review of existing studies supports a 2003 assertion from the U.S. 

General Accounting Office (GAO) that ”... the lack of comprehensive information 

regarding the accuracy of consumer credit reports inhibits any meaningful 

discussion of what more could or should be done to improve credit reporting 

accuracy. Available studies suggest that accuracy could be a problem, but no study 

has been performed that is representative of the universe of credit reports.” 

Avery et al. (2003) examined the contents of 249,000 credit reports from a single credit 

bureau and highlighted problems associated with data that was missing from a file (e.g., 

credit limits on revolving accounts; non-reporting of minor delinquencies), out-of-date 

(e.g., old balance information that had not been updated), and sometimes ambiguous 

(e.g., multiple collection entries but no clear reference as to the number of incidents; 

accounts listed as open but with no recent activity). Another study, sponsored by the 

Consumer Federation of America (2002) and performed in conjunction with the National 

Credit Reporting Association, examined differences across credit reports produced for 
1,700 mortgage applicants by the three major credit bureaus. This study also found 

inconsistencies across three reports for the same person which would lead to different 

credit scores (and risk evaluation). However, neither of these studies was designed to 

identify instances in which a specific item in the credit file was inaccurate at the time it 

was reported. In an older study (1992), the Associated Credit Bureaus (precursor to the 

Consumer Data Industry Association) engaged Arthur Andersen and Co. to follow the 

dispute resolution process for 15,703 randomly chosen consumers who were informed 

that they had been denied credit. About 8% of these consumers requested a copy of their 

credit report to follow up, and about one fourth of these consumers disputed information 

in their file. However, upon reinvestigation (as mandated by the FCRA) only 3% of 

those who had requested their credit report “would have achieved a different credit 

decision than was originally rendered by the credit grantor after initial review of the 

information contained in the credit report.”1

 With more recent risk-based pricing 

practices, a larger percentage of applicants would presumably be affected by similar 

errors in the file, but they would likely be affected to a lesser extent, on average (an 

interest premium being judged as less significant than the rejection of a loan application). 

Staten and Cate cite other statistics provided by the CDIA before the Senate Committee 

on Banking, Housing and Urban Affairs, which show that revisions to credit reports were 

made in response to more than 50% of disputes raised by consumers in 2003, but no 

indication was offered as to the materiality of such changes on assessments of the 

consumers’ creditworthiness. Of the changes to the file, 30% involved removal of items 

which could not be verified within the 30 days required by the FCRA. 

The aforementioned studies thus highlight the technical problems in maintaining the 

integrity of such massive databases and merging them with information from other 

sources. They explain how discrepancies arise among files maintained by the three major 

credit bureaus. They also raise questions about the dispute resolution process. The 

studies were not, however, designed to produce an unbiased assessment of the prevalence 

of errors in consumer credit files, to gauge the severity of their impact on consumers and 

businesses, to determine whether particular members of society (ethnic minorities, the 

elderly or low-income households) are affected disproportionately by such errors, or to 

ascertain whether alleged errors are resolved with reasonable efficiency. 

Staten and Cate succinctly summarize the state of work in this area: 

As the GAO report noted, statistically representative studies that quantify 

the frequency of errors of commission (i.e., the inclusion of items in a 

credit file that do not belong to the consumer) are rare. In large part this is 

because they require (1) a sample of consumers representative of some 

larger population, (2) their cooperation in examining credit reports for 

discrepancies, (3) reinvestigation of alleged discrepancies to determine 

whether the items needed correction, and (4) the involvement of an 

independent arbiter to determine which of the corrected discrepancies are 

relevant to the credit-granting decision. 

 

1

 Arthur Anderson and Company (1992), Executive Summary. 

2
The pilot study was designed to test methods of addressing the various shortcomings of 

prior investigations and meet the recognized challenges. It will also help to provide 

preliminary estimates of the work involved in conducting the national study. 

Considerations in the Study Design 

The design of a large nationally representative study of a thousand or more consumers 

and their credit reports poses several challenges in terms of minimizing problems of nonresponse or attrition when dealing with sensitive personal financial information. In 

addition, we recognize the need for procedures that avoid bias in the dispute resolution 

process. Special attention was given to: 

• Engendering confidentiality, trust and consumer participation. The research 

team expected that many consumers would initially resist participating in a study 

that exposes their financial circumstances to third parties. In addition to a 

reluctance to discuss their credit history and outstanding debt, we expected that 

consumers would likely be concerned about identity theft and misuse of their 

personal information. Explicit FTC endorsement and invitation to participate, the 

credibility of university research centers, and utilization of a highly reputable 

source for credit bureau information were the devices used to increase consumer 

willingness to participate in the study and to engender confidence in the process. 

• Maintaining engagement through a rigorous review of credit files and 

possible dispute resolution. Consumers vary in ability to interpret and digest 

information in credit reports and assess their accuracy. Consumers who agreed to 

participate were involved with university researchers over several weeks or 

months as they obtained their credit reports, reviewed the reports with the 

research team, and took action to resolve alleged errors that were uncovered in the 

review. Generally, a single research associate assumed responsibility for the 

entire process with a particular consumer to provide continuity and reinforce 

commitment. In cases where another research associate was involved for some 

phase of the activity, the participant was given the name of the substituting 

individual. 

• Avoiding potential bias from repository influence. The credit bureaus were 

neither involved in selecting participants nor able to identify them in the dispute 

resolution process. There was assuredly no preferential treatment offered to study 

participants versus the population at large. 

Study Process 

In this section, we relate our experience in executing the research protocol and share 

findings germane to the design and execution of the national study. We relate details on 

the process used to build our candidate list, summarize the yields obtained from 

successive mailings, describe difficulties encountered in efficiently getting documented 

consent and drawing credit reports, relate the processes used to prepare for and conduct 

the intensive reviews of credit-bureau information, and elaborate on the process used to 

track the results of disputes. 

3
The pilot study was initiated with a team meeting in St. Louis on July 21, 2005. The 

principal investigators from the Georgetown University Credit Research Center, the 

University of Missouri-St. Louis, and Fair Isaac Corporation refined the instruments that 

would be used to guide research associates in the telephone recruiting process and in the 

review of the credit reports. Drafts were shared with the FTC and refinements were made 

through subsequent telephone conferences and e-mail communication. In other telephone 

conferences and e-mail exchanges, the research team, in collaboration with the FTC, 

drafted and finalized the recruitment letter and consent form that were used to invite 

participation in the study, authorize the research team to draw the credit reports and 

review them with participants. The consent form also committed participants to inform 

the research team of resulting disputes filed with creditors or the credit bureaus and to 

report the outcomes to the researchers. The FTC worked with the research team to 

establish proper procedures for protection of data and privacy of consumers’ information. 

The protocol employed in the study itself was as follows: 

1. The solicitation letter (Exhibit 1) and consent form (Exhibit 2) from the United 

States Federal Trade Commission (FTC) were sent to 254 households selected 

nationwide to provide a broad socio-economic cross-section of homes in different 

geographic regions. The letter outlined the purpose of the study and encouraged 

participation of an adult with credit history that could be checked in databases of 

national credit bureaus. The FTC letter was followed by a letter from the 

university (Exhibit 3) with further information on the nature of the engagement 

and processes to obtain the credit reports without divulging detailed personal 

information such as SSN or actual account numbers. 

2. A screening interview (Exhibit 4) was conducted over the telephone by a 

university representative to identify eligible participants in the household. The 

eligible person with the most recent birthday was originally indicated as the 

preferred participant if available. This seemed to cause a bit of confusion in the 

early (first 34 pretesting) interviews; so afterwards the person who answered the 

telephone was asked to identify an eligible participant. Assenting individuals 

were asked to mail a signed consent form to the university (in the self-addressed 

and postage prepaid envelope provided), thus authorizing the university to obtain 

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

review them in detail. 

3. After receipt of the signed consent form, the university contacted the participant 

by telephone and sent (by e-mail) instructions (Exhibit 5) with userids and 

passwords for establishing accounts on the Fair Isaac myFICO website through 

which copies of current credit reports with credit scores would be obtained. 

4. Fair Isaac e-mailed promotional codes to the participant, who, in turn, was able to 

“purchase” the credit reports free of charge. The reports were available for about 

30 days for viewing by the participant and the university was able to download 

and print the reports with the designated userid and password. Digits of the 

consumers SSN’s and account numbers were suppressed in the reports to protect 

the consumers’ personal information. 

4
5. One copy of the report was mailed to the consumer’s home address along with a 

brochure describing the content and meaning of information in the credit report 

and a check-list (Exhibit 6) was provided to help the consumer prepare for the indepth review. Another copy of the report was retained by the university for 

succeeding steps in the study. 

6. University research associates performed a cross-bureau comparison of 

information furnished in the three credit reports and created an Excel spreadsheet 

(Exhibit 7) that summarized key elements from each report that influence the 

individuals’ credit scores. 

7. With reference to the summary spreadsheet and an interviewing guide (Exhibit 8), 

university research associates conducted an in-depth telephone interview with the 

participant to review the credit report and to identify alleged errors. 

8. Participants were informed of procedures for challenging information that appears 

to be erroneous in credit-bureau files. With reference to descriptive information 

in the myFICO credit-report summary, participants were especially reminded of 

the types of errors that would likely have a significant impact on their credit 

scores (and therefore possibly affect their access to or cost of obtaining further 

credit). In instances where participants indicated that they may register disputes, 

an e-mail was sent to the participants with further information about the dispute 

process (Exhibit 9). 

9. Alleged errors were classified for statistical summaries. 

10. In instances where a material change in credit standing might occur with 

correction of alleged errors (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), the university team tracked the 

results of disputes lodged by consumers. Alleged errors were marked on the 

university’s copy of the credit report and a copy was forwarded to Fair-Isaac for 

re-scoring against the original credit report. A second credit report was drawn 

(with at least six weeks to allow corrections to be made) by the same process and 

checked to see if promised corrections had been applied. 

11. Outcomes were classified for statistical reporting. 

Recruitment 

Recruitment letters were sent to 254 households in a series of seven mailings. The first 

mailing went to 34 households in the metropolitan St. Louis area (the home of UM-St. 

Louis) to serve as a pretest of the engagement process. Households were chosen with the 

help of online reverse telephone directories and property assessment records to provide a 

cross-section of socio-economic characteristics in suburban and urban neighborhoods. 

Individuals from seven households (21%) in the St. Louis area agreed to participate 

without any financial inducement and six completed the process. Because the recruiting 

yield met our expectations without financial inducement (beyond the free credit reports 

and credit scores), we decided to continue the recruitment process without offering 

financial incentives. 

5
The succeeding six mailings were conducted similarly to reach consumers nationwide. 

The percentage of people who were contacted and who then agreed to participate (the 

recruiting yield in Table 1) varied slightly among mailings, but well within the range of 

normal statistical variation. In other words, there was no discernable deterioration in 

recruiting success as the net was cast farther from home base of the institution from 

which recruiting took place. The eventual sample had representation from 22 states 

including Alaska. Only Missouri (home of the pretesting interviews which were included 

in the sample) had more than two households represented. 

In the initial contacts, there was no pervading mistrust expressed about the motive of the 

telephone recruiter. The FTC reported only two calls to their help line from individuals 

who were inquiring about the authenticity of the study. The FTC provided the necessary 

assurance to those individuals. Approximately one contact in five declined forcefully 

because they did not want to be bothered. Some (perhaps a dozen) had recently checked 

their credit reports on their own and declined to participate. The vast majority recalled 

seeing the letters mailed from the FTC and from the university. A couple of individuals 

did not recall receiving the materials (due to change of address in one case, but with a 

retained telephone number) but they were willing to be part of the study. We sent followup letters and consent forms when such interest was expressed – sometimes by e-mail. 

After agreeing to take part in the study, the participants were to mail the signed consent 

form to the university. This occurred without telephone reminders in fewer than half the 

cases. If the consent form was not received within a week, the recruiter called with 

reminders and, in about 30% of the cases, we had to send another copy of the consent 

form by fax or regular mail. In 20% of the cases where people had agreed to participate 

in the initial telephone interview, consent forms were never received by the university 

and we stopped following up after our study quota of 30 individuals was reached. This 

suggests that the initial assent is sometimes tentative and possibly the subject of further 

family discussion. Mailing the consent form may also be an easily neglected task if 

interest in participating is lukewarm. In any case, there seems to be an attrition of about 

20% at this stage, even with aggressive telephone follow-up. 

Mechanics of Acquiring Credit Reports and Credit Scores 

The next stage in the recruitment process was the establishment of the myFICO online 

accounts with Fair Isaac through which the credit reports were to be obtained. Another 

series of contacts were required (some by e-mail and some by telephone) to help 

individuals navigate the myFICO website in a manner that would allow the credit reports 

to be drawn without divulging their SSNs to the university researchers, and in a manner 

that gave Fair Isaac assurance that the recipients of the credit reports agreed to their 

published terms and conditions under the FCRA. There were instances where consumers 

did not establish their accounts (with the userid’s and passwords provided by the 

university) in a timely fashion and would have to be called for reminders. A few 

consumers (three or four) used their own choice of userid or mistyped the given userid 

and calls were necessary to sort that out so that the researchers could get access to the 

credit reports. Many consumers found the website confusing for the purpose at hand and 

6
abandoned their attempts to navigate it. Only three or four managed to accomplish the 

task on their own despite our mailing explicit instructions and screenshots. Only with 

intensive follow-up, were we successful in getting each of the participants registered. 

Because of the limited budget for the pilot study and the small number of participants to 

be engaged, Fair Isaac could not justify creating a secured website expressly for the 

purpose of the study. Technical staff at Fair Isaac were very helpful in resolving 

difficulties, but they worked in normal business hours while the consumers were typically 

involved in the process outside normal business hours. A specially designed website to 

reduce difficulties, or an alternative procedure whereby the university could acquire 

reports on behalf of the consumers, would therefore enable a much more efficient 

execution of the study protocol. 

After we received the consent forms and advised the consumers on the process for 

establishing accounts, Fair Isaac sent (by e-mail) a promotional code to each participant 

with which the three credit reports and credit scores were to be purchased. Once the 

consumer had completed the purchase (using the userid and password provided by the 

university), the university could print the credit reports and mail them to the participants. 

Again, some intensive follow-up was required to ensure that the consumers completed 

the transaction. Most would do so within three days of receiving the promotional code, 

but some required follow-up over three weeks. Interviews were typically scheduled 

within a week after the reports were mailed (by first-class U.S. postal service). Some 

(five or six) had to be postponed because of delays in delivery of the mail; others had to 

be postponed because the consumers acquired higher priority commitments in the 

meantime. For each credit report printed, Fair Isaac was given the logonid (account 

designator) so that a frozen file could be preserved for rescoring if necessary. In-depth 

interviews were successfully completed with every participant for whom credit reports 

had been drawn. The net results of the recruitment and engagement efforts are presented 

in Table 1. 

Table 1 – Net Success Rates for Recruitment and Engagement 

Letters W illing Recruiting Consent A ccounts Review s Percent

Mailed to Participate Yield Received Established Com pleted Engaged

List I 34 7 20.6% 7 6 6 17.6%

List II 40 5 12.5% 5 3 3 7.5%

List III 40 9 22.5% 7 5 5 12.5%

List IV 30 5 16.7% 2 2 2 6.7%

List V 50 10 20.0% 7 7 7 14.0%

List VI 40 7 17.5% 6 4 4 10.0%

List VII 20 3 15.0% 3 3 3 15.0%

Total 254 46 18.1% 37 30 30 11.8%

As seen in the statistics in Table 1, we successfully engaged and completed in-depth 

reviews of the credit reports with individuals in 30 of the 254 households (12%) targeted 

for possible participation. 

7
We further examined the involvement and retention at each stage of the research 

protocol. This was intended to identify steps at which procedural improvements may 

increase efficiency and to enable a rough estimate (from a small sample size) of the scale 

of outreach required to provide a representative sample in a national study. This 

information is summarized in Table 2. 

Again, in Table 2, we note that letters were mailed to 254 households. As of June 7, 

letters from 19 households had been returned to the university or to the FTC as 

undeliverable. Telephone contact was made with individuals in 175 households (69% of 

the total targeted). In the course of the initial recruiting interval, 46 (26%) expressed a 

willingness to participate in the study. Properly executed consent letters were received 

from 37 individuals (80% of interested participants). Of those individuals, 30 (81%) 

established accounts at myFICO.com. We managed to mail the reports and complete the 

interviews for all 30 (100%) of those who established the myFICO accounts. We thus 

obtained comprehensive reviews of the credit files for 12% of the targeted households. 

Table 2 – Involvement at Successive Stages 

Stage in Research Protocol Number Marginal Cumulative

Percent Percent 

Letters mailed 254 100 100 

Telephone contact made 175 68.9 68.9 

Expressed interest in participating 46 26.3 18.1 

Provided signed consent 37 80.4 14.6 

Established accounts 30 81.1 11.8 

Purchased credit reports 30 100.0 11.8 

Completed in-depth review 30 100.0 11.8 

Expressed intention to dispute 7 23.3 2.8 

Provided evidence of filing dispute 1 14.3 0.4 

Provided documentation of results of 

dispute 

1 100.0 0.4 

There are probably many reasons for completing the engagement with just 65% of the 

individuals who expressed initial interest. In one case a consumer called in response to 

follow-up phone messages and e-mails to apologize. Her house had burned to the ground 

as a result of teenage vandalism, but she was willing to take part when things returned to 

normal – perhaps late August. In another, we were told that a person’s travel schedule 

had become so intense that he did not have time to participate. In another, a person’s 

business affairs had taken him out of the country. Some of the initial interest may have 

been tentative or a polite brush-off. Some attrition may have been due to the difficulty of 

catching people who are employed outside normal business hours. Caller ID enables 

individuals to avoid callbacks that they wish not to receive; so we cannot provide more 

definitive reasons for our failure to keep all the initially interested parties engaged 

8
through the entire process. We judge, however, that a simplified process for registering 

consent (perhaps electronically) and better mechanics for establishing accounts and 

drawing the credit reports could improve participation rates considerably. 

In summary, there is considerable room for streamlining recruitment, obtaining consent 

and drawing credit reports, but it is clear that consumers can be engaged successfully in 

the process without financial incentives. 

Preparing for In-Depth Review of the Credit Reports 

Thorough preparation by the interviewer is essential for an effective review of the credit 

reports, as the consumers themselves vary greatly in their own preparation. Preparation 

begins with a systematic review of the credit reports to identify: 

• 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 

o installment loans 

o revolving credit (home equity lines of credit, 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. 

To assist in the interview, a spreadsheet (Exhibit 7) was produced to summarize the 

critical information in the reports from the three bureaus. Each spreadsheet was 

individually constructed with the same basic template, but augmented as appropriate to 

include relevant information for the individual consumer. In preparing the spreadsheet, 

the researcher started with information from the credit bureau that had most information 

on file (usually the one with the lowest credit score), and then extracted corresponding 

information and complementary information from the other bureaus’ reports. 

9
To help the consumer prepare for the interview in a similar manner, we mailed a checklist 

(Exhibit 6) with the copies of the credit reports. Some consumers prepared meticulously 

and enabled a thorough 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 (30-45 

minutes), but 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 (and median) of 28 minutes, with 90 percent taking between 15 and 45 

minutes. The participants reported taking an average of 73 minutes (median of 60 

minutes), with 90% taking between 15 and 270 minutes) to prepare for the interview. 

Conducting the In-Depth Reviews of the Credit Reports 

Armed with the checklist of items to cover in the report (Exhibit 6), the summary 

spreadsheet of items reported (Exhibit 7) and the interviewing guide (Exhibit 8), 

university research associates conducted the telephone interview with the consumer and 

made notes of items that the consumer thought may be erroneous. Care was 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 posed 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 guessing as to whether an account should be considered to be currently 

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

In the early stages, the interviewers relied heavily on the interviewing guide (Exhibit 8) 

to structure their discussion, but as they gained experience and improved the spreadsheet 

summary, they relied more on the individualized spreadsheets (Exhibit 7), the reports 

themselves, and on the checklist (Exhibit 6) to structure their interviews. 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 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). Results 

of rescoring were not to be shared with the consumers. 

10
After conducting the interview, the research associate summarized the findings to ensure 

that the consumer’s perspective was understood. In situations where errors were alleged 

and where the consumer indicated that he or she might consider filing a dispute, the 

research associate briefly discussed the options available and sent an e-mail to the 

consumer with information about filing disputes (Exhibit 9). 

A summary record of the interview 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 

logonid (without password), the birthdate for computing the age of the consumer, the 

gender of the participant, ZIP code of residence and standard demographic characteristics 

obtained from the recruitment survey (or from a follow-up survey requesting the same 

data). The demographic data allow us to characterize the composition of the sample. 

The contents of the SAS dataset created to summarize the credit-bureau information and 

the outcomes for each participant are presented in Exhibit 10. 

Disputes and Dispute Resolution 

Participants agreed to provide copies of the related correspondence between themselves 

and creditors or credit bureaus if they filed disputes. About one month after completion 

of the review of the credit report, we sent an e-mail letter (Exhibit 11) to each consumer 

who indicated that they were considering filing a dispute and made a follow-up phone 

call to any (one, in this case) consumer who had provided evidence of filing a dispute. 

Having received just one response to the e-mail inquiry as the end of the pilot study 

approached, we added a final step to the research protocol in which we called participants 

to confirm outcomes and gather their impressions of the review process. 

Final Assessment 

As mentioned above, we added a final step to the study protocol to make sure that there 

was no unreported dispute activity, to obtain missing demographic data for some 

participants, and to obtain an assessment of the process from the perspectives of the 

participants. We called each of the participants a final time to execute the assessment 

survey (Exhibit 12) and added any missing information to the SAS database. Every 

participant in the study was satisfied with the review process and judged the review as 

thorough. 

11
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 and to compare the 

characteristics of the sample with those of the population at large. 

The distributions of credit scores in the sample appear in Table 3a. and 3b. The score 

ranges in Table 3a were selected to approximate the quintiles in the universe of credit 

scores as inferred from the information provided in the credit-bureau reports. 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 tendency to engage individuals 

whose credit histories produce higher than average credit scores. 

Another way of looking at the distribution of scores is to compare the sample frequencies 

with those in fixed intervals that emanate from the scoring process in general. With 

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

frequencies in 50-point intervals in Table 3b. The implications, of course, are the same. 

The sample contains a greater proportion in the upper intervals and a smaller proportion 

in the lower intervals. 

Table 3a - Distribution of Credit Scores for Participants 

Score Range Bureau A

(percent) 

Bureau B

(percent) 

Bureau C

(percent) 

Total 

(percent) 

Under 610 3 

(10.3) 

1 

(3.5) 

2 

(6.9) 

6 

(7.0) 

610-689 5 

(17.2) 

8 

(27.6) 

7 

(24.1) 

20 

(23.0) 

690-749 5 

(17.2) 

5 

(17.2) 

4 

(13.8) 

14 

(16.1) 

750-789 8 

(27.6) 

2 

(6.9) 

4 

(13.8) 

14 

(16.1) 

790 plus 8 

(27.6) 

13 

(44.8) 

12 

(41.4) 

33 

(37.9) 

12
Table 3b – Comparison of Score Distributions for Fixed Intervals in Credit Scores 

Score Range Sample

percent

Bureau 

percent

Under 600 7 13 

600-649 6 12 

650-699 18 15 

700-749 15 20 

750-799 25 28 

800 plus 29 13 

The sample consisted of 17 women (57%) and 13 men (43%). Each of the households 

were reported to have total incomes in excess of $25,000, although several had 

undergone periods of financial stress and lower incomes (from unemployment and 

medical problems) that were reflected in the recent credit history. Six households (21%) 

reported household incomes in excess of $100,000. Most of the participants (45%) were 

in the 55-64 age group. Twenty-eight (93%) were white. Seventy percent were currently 

married and half the sample had college degrees. A disproportionate number were 

classified as being in professional occupations or employed with managerial or 

administrative responsibilities (65%). 

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. We also retained the assessed real-estate valuations of each of the individual 

targeted households with the expectation that it would add precision to the analysis of 

response rates and adaptation of recruiting strategies. Alternative recruiting strategies 

(such as through credit counseling services or other public services) might also be needed 

to increase participation of individuals with lower credit scores and from groups with 

lower socio-economic status. Requiring the consumer to use the internet to participate in 

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

With a small sample sparsely distributed nationwide, we do not have sufficient data to 

investigate the relationships among household characteristics, participation rates, credit 

scores and error rates. An expanded pilot (taking the sample size above 150) would 

enable preliminary investigation of such relationships. A national study would allow an 

in-depth investigation. 

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 produced a consolidated assessment of the accuracy of the credit records for 

13
each participant. Specifically, we noted whether there was a significant error (other than 

typographical information) in each of: 

• current address 

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

affiliation) 

• employment history (citing an employer for whom the person had not worked) 

• reporting of invalid accounts (accounts that were allegedly not belonging to or 

cosigned by the participant) 

• reporting of incorrect balances on accounts (beyond balance ranges in the 

reporting period) 

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

• reporting of negative items (late payments) 

• number of accounts with nonzero balances 

• number of public derogatories (e.g., bankruptcies) 

• accounts submitted for collection and current balances thereon 

• revolving credit utilization. 

In Table 4, we provide statistical summaries of error rates and the research team’s 

judgment of their potential materiality (before rescoring of the credit reports). Counting 

the number of instances of alleged errors of any kind, we had 14 consumers (47%) with 

no errors alleged in any of the bureau files. Eight consumers (27%) alleged one type of 

error. Seven consumers (23%) alleged two types of error. One consumer (3%) alleged 

that three types of error were present in his credit reports. The majority of consumers (16 

out of 30) asserted that something was incorrect in their credit records. Several cases 

with alleged errors involved wrong addresses or employment information that would not 

affect a consumer’s credit score. 

Two faculty investigators examined the credit reports and considered the nature of the 

alleged errors in conjunction with the current credit scores to assess whether the error 

should be classified as material. Two criteria dominated this judgment. First, the error 

was classified as material if it seemed likely that correction of the record would have a 

materially beneficial effect on the credit score. Secondly it was classified as material if 

the investigators agreed that it would seem to protect the consumer against a significant 

risk of identity theft (as with the presence of an account not belonging to the consumer or 

exposure to future damage in the credit record from other information wrongly tied to the 

file). While this process admittedly injects a subjective element into the study, we shall 

see below that the ability to determine whether an error has “material” impact on a 

consumer’s credit profile is helpful for identifying cases for additional follow-up effort in 

tracking consumer actions (or inaction) taken to resolve alleged inaccuracies. 

Examining whether the errors could have a significantly detrimental effect on the 

consumer’s credit standing, the researchers judged that there was a reasonable likelihood 

of a material improvement in credit standing in three cases (10% of those studied) if 

further investigation should validate the consumers’ claims. In two other cases, the 

researchers assessed a smaller (but nonnegligible) likelihood that correction of the 

alleged errors would materially improve the participant’s credit scores. It must be 

14
emphasized that these statistics represent the mere possibility of material errors 

uncovered from the initial review. The consumers themselves may, after further 

investigation on their own, discover the reason for the alleged anomalies and decide not 

to register disputes. Careful follow-up of their actions after the review is therefore 

required to get a complete picture. Further, these statistics are based on a very small 

sample and are presented for illustrative purposes only. 

Table 4 – Types of Error and Judgments of Materiality 

(Prior to Rescoring and Dispute Validation) 

Number of Error 

Types Alleged 

Likely 

Material

Effect 

Not Likely

Material 

Effect 

Unsure of 

Materiality

Total Number 

of Instances 

0 0 14 0 14 (47%) 

1 2 6 0 8 (27%) 

2 1 4 2 7 (23%) 

3 0 1 0 1 (3%) 

Total (pct) 3 (10%) 25 (83%) 2 (7%) 30 

With the data collected, we can examine accuracy and actions taken by consumers on a 

number of dimensions. In Table 5 we show the classification of outcomes according to 

average credit score for the consumer. Perhaps not surprisingly, the percentage of 

consumers without allegations of material errors is much greater among those with high 

credit scores. Conversely, the percentage of consumers with allegations of material 

errors is higher among those with low credit scores. 

Next we consider the reactions of consumers upon identifying discrepancies in the credit 

reports. At the end of the in-depth review, the research associate summarizes the findings 

and asks if the participant is inclined to register a dispute of the items brought into 

question. In Table 6 we summarize those expressed intentions according to the 

materiality assessments of the research team (that were made on the basis of the statistical 

extract from the interview). Each of the three respondents (100%) with potentially 

material errors indicated at the end of the interview that they intended to file disputes. 

Two individuals without errors of material magnitude indicated that they will ask that the 

minor items be corrected (e.g., an account shown as closed in a file with no bankruptcies 

or public derogatory but with bankruptcy stated as one possible reason, or with 

explainable reasons for a wrong address such as rental property or relative’s address). 

The two consumers with alleged errors in the credit records, but of a magnitude to make 

the faculty researchers unsure whether they would have a material effect on the credit 

scores, said that they intended to file disputes. 

15
Table 5 – Allegations of Errors according to Credit Score Groupings 

Credit 

Score 

Category 

Likely 

Material 

Effect 

Not 

Likely 

Material 

Effect 

Unsure of 

Materiality

Percent with No 

Alleged Errors 

Likely to Affect 

Creditworthiness

Percent with 

Alleged Errors 

Judged Likely to 

Affect 

Creditworthiness 

Under 610 1 0 1 33.3 33.3 

610-689 2 5 1 82.5 25.0 

690-749 0 5 0 100 0 

750-789 0 2 0 100 0 

790 plus 0 13 0 100 0 

Total (pct) 3 (10%) 25 (83%) 2 (7%) 

As mentioned earlier, consumers may investigate matters on their own and decide not to 

file disputes, or they may feel that the process is too cumbersome to make it worthwhile. 

Consequently, before any final judgment is made regarding the accuracy of credit report 

content, it is crucial to determine consumers’ subsequent actions taken to resolve disputes 

and to examine the resulting impact upon the credit records. 

Table 6 – Expressed Intentions to File Disputes 

(Row Percentages in Parentheses) 

Presence of 

Material Error 

Plan to 

File Dispute

Do Not Plan

To File 

Dispute 

Unsure of 

Dispute 

Intention 

Yes 3 

(100) 

0 

(0) 

0 

(0) 

No 3 

(12.0) 

21 

(84.0) 

1 

(4.0) 

Unsure 2 

(100) 

0 

(0) 

0 

(0) 

Total 7 

(24.1) 

21 

(72.4) 

1 

(3.5) 

Following Disputes 

There were only two consumers as of June 14 who had informed the researchers that they 

had actually filed formal disputes. One consumer filed the dispute with his bank, 

claiming that the bank had made a processing error in applying a payment to the wrong 

account. Within just a few days of his interview he faxed to the university a copy of a 

letter from his bank apologizing for the processing error and assuring him that the credit 

records would be corrected. A new set of credit reports was finally drawn on June 14 

(after a half dozen calls and e-mail messages to the consumer with requests to purchase 

the new credit reports with the second promotional code sent to him by e-mail). The 

16
disputed item had been removed from two bureau reports that had contained the error. 

The new credit scores from the affected bureaus increased accordingly (by 103 points and 

100 points) respectively. The score for the unaffected bureau had changed by 54 points, 

presumably because of other interim changes in the consumer’s credit profile. The 

sizeable increases in credit scores from the affected bureau files, relative to the unaffected 

bureau score, is consistent with the researchers’ judgment that correction of the error 

would have a material effect in this case. 

The other individual, in the follow-up interview, reported that she had used the online 

service of the single credit bureau with whom she had a dispute. She claims to have 

received no communication from the bureau as a result. She claims also to have acquired 

a credit report from that bureau two months later and that there was no change to the 

record. She did not furnish us with hard-copy evidence of the transactions. 

Two other participants planned to file disputes but had not done so three months after 

their review of the credit reports. We managed to reach both these individuals to discuss 

why they had not filed the disputes as intended. One of these persons had reported errors 

that were judged to have a potentially material effect on the person’s credit scores. The 

other individual alleged errors of a type that left us unsure about their impact. The former 

said that she was overwhelmed as a single mother with twins and could not muster the 

time to file a dispute. The latter similarly said that her life was too busy to take the time 

and she did not know when or whether she would get to it. When asked if they were 

discouraged by the thought that filing a dispute would have no significant impact on their 

credit scores, both individuals denied that this affected their behavior. When asked 

further if they would have signed and mailed paperwork for the dispute process if it had 

been prepared for them by the research associates and mailed a couple of months after 

their review of the credit reports, both individuals said that they would have done so. 

The case where the person claimed to have tried to file a dispute unsuccessfully via an 

on-line process, and the two cases of unfulfilled intentions illustrate that the task of 

following the results of disputes poses a greater problem than we expected. We expected 

that participants would be motivated to have any errors in their credit records corrected 

promptly. This did not generally occur. It underscores the need for adding follow-up 

interviews as part of the protocol to determine why disputes are not filed when errors are 

alleged. As we mentioned earlier, some consumers may discover that their recollections 

in the review of the credit reports were mistaken. Others may be deterred because they 

do not have time to go through the process or do not expect significant benefits from the 

exercise. We strongly recommend that for a national study, a follow-up interview should 

be conducted with consumers whose credit reports are alleged to contain errors that are 

judged by the researchers to be potentially material in magnitude, but who do not provide 

evidence (related correspondence) of filing a dispute. Consideration might also be given 

to facilitating the process, perhaps by having the research assistants prepare the relevant 

paperwork after the review of the credit reports and mail it to the participants for their 

perusal and signature. Such a mailing could be done after a couple of months, thus 

giving the researchers some opportunity to assess the extent to which errors may go 

uncorrected because the consumers fail report them. 

17
Information Generated for Analyzing Errors and Assessing Bureau Consistency 

The methodology employed in the pilot study provides information for a thorough 

analysis of the accuracy of information placed in credit-bureau files and presented in 

credit reports. It also provides the necessary information for a penetrating analysis of the 

consistency of information across the three major credit bureaus. In this section, we 

present some statistics from the pilot study to show the types of specific information that 

could be garnered from the national study using this study methodology. Again, the 

statistics are for illustrative purposes only. The sample size of 30 is much too small to 

be a reliable indicator of information in the universe of credit reports. Beyond the 

assessment of errors as material or not, there are many questions that a national study 

based on this methodology could address. Examples are: 

• What is the specific nature of the errors alleged by consumers? Do certain 

categories of credit report information generate more frequent concerns? 

• Are the alleged errors present in the credit reports of more than one bureau? 

• After further examination, did the consumers take initiative to have the errors 

corrected (i.e., did they file a formal dispute)? A follow-up questionnaire could 

probe further as to why the consumers who intended to file disputes did not do so. 

• How consistently did the credit bureaus represent the creditworthiness of 

consumers? In addition to variation in credit scores derived from the creditbureau files, we can assess consistency in reporting 

o Personal information such as addresses and employment status 

o Length of credit history 

o Late payments 

o Public derogatories 

o Implied utilization of revolving credit 

o Responsible discharge of mortgage debt 

o Responsible discharge of installment debt 

o Collection activity and results of collection activity 

To illustrate the type of statistical information that can be produced from this research 

design, we list some of the critical pieces of information for each of the 30 participants. 

Then we offer a few illustrative statistical summaries directed to the questions above. All 

of this information was extracted from the de-identified SAS database with summary 

information extracted from the credit reports by the research associates and faculty 

investigators. The case number is used to identify the study participant and may be used 

to correlate information in the different tables that follow. 

In Table 7 we show, for each study participant, the number of credit reports that could be 

drawn, the minimum credit score from any bureau, the maximum credit score for any 

bureau, the range in credit scores, the number of types of errors alleged on the in-depth 

review of the credit report, whether the consumer planned to file a dispute, and whether 

the faculty researchers judged the alleged errors to have a material effect on the 

consumer’s creditworthiness (eligibility for credit based on the credit score). If, for 

example, all the scores placed the consumer in the top 2% of borrowers, a correction of 

18
the error was not deemed to have a material effect unless there was an error that 

suggested the potential for contamination from another consumer’s information (as with 

open accounts that did not belong to the consumer). In one case, only one out of three 

bureaus reported a minor delinquency that was six years old, but that bureau’s credit 

score was already the highest of the three scores, suggesting that the old delinquency was 

exerting little, if any, negative effect on the score. Consequently, correction of the record 

was judged not to have a material effect. 

In Table 8 we show, for each study participant, which of the specific errors were alleged 

to have occurred in one of the three bureau files. Excluding the personal identification 

fields, the categories of credit report information with the most frequent allegations of 

problems involves the presence and frequency of delinquency information, with eight out 

of 30 respondents alleging inaccuracies in that item. The last column in Table 8 pertains 

to the degree to which a consumer has utilized his currently available revolving credit 

lines. The bureaus did not report a summary ratio of revolving credit balance to 

revolving credit limit. Instead, we computed the ratio for each bureau’s file by summing 

the credit lines and current balances for credit cards, home equity lines of credit, and 

other accounts labeled revolving. For purposes of judging whether an alleged error 

regarding utilization rates was material, we used the following criteria. If no error was 

reported in revolving account balances and if the utilization percentages computed from 

all bureaus’ data were within 10% of each other, or if the maximum account utilization 

was less than 20%, we concluded there was no material error in the degree to which a 

consumer was utilizing his revolving credit lines. This criterion could, of course, be 

adjusted with further research. 

We subjected cases in which consumers said they planned to file disputes (other than 

errors in address or employment information, which would have had no impact on credit 

scores), and cases thought to have a potentially material impact on credit score, to further 

scrutiny and made them candidates for rescoring to confirm whether the errors would 

have had a material impact. Changes to correct the errors were imposed on the credit 

reports and they were sent to Fair Isaac for “rescoring”. 

The rescoring process for the pilot study was just partially automated. Changes were 

imposed on a computerized file and the values of the predictive variables for the 

MYFICO scoring models were recomputed for each of the credit bureaus with alleged 

errors. A Fair Isaac expert noted the marginal changes that would have occurred in the 

computation of the credit scores and finished the revisions manually. In a national study, 

this process would be completely automated. 

19
Table 7 - Credit Score Ranges, Number of Errors Alleged, Plans for Dispute and Assessments of Materiality 

 20:57 S no. of minimum maximum range in no. of plans to errors  scores credit credit credit alleged register judged  case avail. score score scores errors dispute material  1 3 659 680 21 2 YES YES  2 3 649 700 51 2 NO NO  3 3 806 835 29 1 NO NO  4 3 560 626 66 2 YES UNSURE  5 3 651 672 21 2 YES UNSURE  6 3 794 821 27 0 YES NO  7 3 810 820 10 0 NO NO  8 3 782 810 28 1 NO NO  9 3 769 783 14 2 UNSURE NO  10 3 753 783 30 1 UNSURE NO  11 3 722 733 11 0 NO NO  12 3 800 815 15 1 NO NO  13 1 688 688 . 0 NO NO  14 3 784 808 24 0 NO NO  15 3 791 815 24 0 NO NO  16 3 785 840 55 0 NO NO  17 2 585 651 66 0 NO NO  18 3 699 774 75 3 NO NO  19 3 701 729 28 1 NO NO  20 3 797 808 11 0 NO NO  21 3 667 682 15 0 NO NO  22 3 801 814 13 0 NO NO  23 3 705 727 22 1 NO NO  24 3 799 820 21 3 YES NO  25 3 788 799 11 2 NO NO  26 3 704 724 20 0 NO NO  27 3 764 819 55 0 NO NO  28 3 658 672 14 1 YES YES  29 3 530 541 11 1 YES YES  30 3 615 626 11 0 NO NO 

20
 Table 8 - Specific Types of Errors Alleged by Participants 20:57 Sunda

 error in error in error in invalid invalid wrong error in error in error in error  current previous employment account(s) acc.balance credit no. of neg nonzero no. of amt.  case address addresses history reported reported inquiries items balances public derogs. to co 1 NO YES NO NO UNSURE NO NO NO UNSURE YES  2 NO YES NO NO NO NO YES NO NO NO  3 NO YES NO NO NO NO NO NO NO NO  4 NO NO NO NO NO NO YES NO NO YES  5 NO YES NO NO NO NO YES NO NO NO  6 NO NO NO NO NO NO NO NO NO NO  7 NO NO NO NO NO NO NO NO NO UNSU 8 NO YES NO NO NO NO NO NO NO NO  9 YES YES NO NO NO NO NO NO NO NO  10 NO NO NO NO NO NO YES NO NO NO  11 NO NO NO NO NO NO NO NO NO NO  12 YES NO NO NO NO NO NO NO NO NO  13 NO NO NO NO NO NO NO NO UNSURE NO  14 NO NO NO NO NO NO NO NO NO NO  15 NO NO NO NO NO NO NO NO NO NO  16 NO NO NO NO NO NO NO NO NO NO  17 NO NO NO NO NO NO NO NO NO NO  18 YES YES NO NO NO NO YES NO NO NO  19 NO YES NO NO NO NO NO NO NO NO  20 NO NO NO NO NO NO NO NO NO NO  21 NO NO NO NO NO NO NO NO NO NO  22 NO NO NO NO NO NO NO NO NO NO  23 NO YES NO NO NO NO NO NO NO UNSU 24 NO YES YES YES NO NO NO NO NO NO  25 NO NO NO NO YES NO NO YES NO NO  26 NO NO NO NO NO NO NO NO NO NO  27 NO NO NO NO NO NO NO NO NO NO  28 NO NO NO NO NO NO YES NO NO NO  29 NO NO NO NO NO NO YES NO NO NO  30 NO NO NO NO NO NO NO NO NO NO 

21
In Table 9 we indicate, for the eight resulting cases, the apparent severity of the error and 

whether the errors appeared in one, two or three bureau reports. There were three 

instances in which alleged errors in the bureau records were judged to be of material 

magnitude. In one of those cases the dispute would have to be filed with a single bureau. 

In another, two bureaus would have to be involved. In another, three bureaus would have 

to be involved. Similar statistics are presented for instances where the alleged errors were 

judged to have a marginal or uncertain effect on aggregate measures o creditworthiness, 

and for instances where the errors were not judged to be material. Overall, errors were 

alleged to appear in all three bureau records in three of the eight cases (37%), in two of 

the three bureau records in three instances (37%) and in only one bureau file in two 

instances (25%). There was no discernable difference in the number of credit bureaus 

that would have to be contacted to remedy minor errors versus errors judged as 

potentially material. 

Table 9 - Number of Bureaus with Disputed Information 

For Errors of Different Degree 

Material 

Error 

One 

Bureau 

Involved

Two 

Bureaus 

Involved

Three 

Bureaus 

Involved

Yes 1 

(33%) 

1 

(33%) 

1 

(33%) 

Unsure 0 

(0%) 

0 

(0%) 

2 

(100%) 

No 1 

(33%) 

2 

(67%) 

0 

(0%) 

Total 2 

(25%) 

3 

(37%) 

3 

(37%) 

We shall not perform detailed analyses of frequencies of errors of specific types because 

we have a very small sample. It should be evident, however, that the data extracted from 

the credit reports, coupled with the consumers’ demographic information and information 

garnered through the dispute process will enable an extremely comprehensive analysis of 

the accuracy of credit-bureau information, and the impact of inaccuracies on consumers’ 

potential eligibility for and cost of credit. 

Because not all creditors report information to all three bureaus, and because creditors 

may report to bureaus on different days, there are inevitable variations in measures of 

consumers’ creditworthiness that can be derived from individual bureaus’ information. 

With information derived from our research protocol, it will be possible (in a national 

study) to determine the extent to which erroneous information contributes to those 

differences. One simple analytical approach would be to compare variances among 

bureau scores between cases with alleged errors versus cases without alleged errors. This 

analysis can be refined further at different stages of the dispute process - identifying first 

the cases with alleged errors judged to be potentially material, then alleged cases verified 

22
to be potentially material (through retrospective rescoring), and so on through the dispute 

process (considering errors affirmed and corrections applied versus others). Of course, 

this is possible only with a study that involves consumers in credit report evaluation and 

dispute resolution. 

To illustrate, in Table 10 and Table 11, we show how several key items used to judge 

creditworthiness of consumers varied among the credit bureaus for the 30 pilot study 

participants. These tables give the maximum and minimum values across the three bureau 

reports for selected items. Table 10 illustrates variations in several measures of credit 

utilization. Table 11 illustrates variations in several negative indicators of past payment 

behavior or other derogatory information. Given the ranges of values for the critical 

indicators of creditworthiness, it is not surprising to see variations across bureaus in the 

resulting credit scores for an individual consumer. Note that in Table 11, “negative 

items” refers to the number of instances (accounts) with late payment information. 

Effects of Errors on Representations of Consumers’ Creditworthiness 

We took pains in this study to distinguish between errors that may substantially affect 

assessments of a consumer’s creditworthiness and those that do not. We used the Fair 

Isaac (FICO) credit score as the standard for this assessment. The credit score is derived 

to indicate the likelihood that a consumer will become seriously delinquent on his or her 

credit obligations, and therefore likely to default. In this study, the materiality judgment 

occurred informally at an intial stage and formally at four additional stages. First, an 

informal assessment must be made by the interviewer at the completion of the end of the 

in-depth review of the credit reports. Sometimes the participants ask whether filing a 

dispute is likely to improve their credit score. The research associates directed the 

participants’ attention to descriptive material provided with the credit report (which did 

not always match the information in the particular report) and explained the items that 

generally have a significant effect on the credit score. They purposely refrained from 

being overly directive, as we wanted to get an idea of how consumers would respond to 

the information in credit reports on their own. Arrangements were discussed with the 

consumer for keeping the researchers informed about the dispute process. 

23
 Table 10 - Variations in Credit Bureau Information on Credit Utilization 

 12:58 Wedn no. of min years max years minimun maximum min no. max no. minimum maximum min  scores credit credit tot credit tot credit nonzero bal nonzero bal mortgage mortgage rev  case avail. history history bal bal accounts accounts bal bal ut 1 3 23 23 209914 210059 5 5 197048 197193  2 3 13 13 332708 333240 2 3 327143 327909  3 3 20 20 1132 1132 2 2 0 0  4 3 11 11 14897 19894 3 4 0 0  5 3 18 18 293450 293756 9 9 240893 241199  6 3 20 27 440 440 3 3 0 0  7 3 23 23 1347 1347 1 1 . .  8 3 23 23 304326 305133 8 9 240911 240911  9 3 17 17 3139 13527 1 3 . .  10 3 13 18 167379 167548 4 4 136177 136346  11 3 22 22 159140 159140 6 6 153325 153325  12 3 27 27 542 1286 2 3 0 0  13 1 29 29 1064217 1064217 6 6 1048023 1048023  14 3 21 21 95350 97861 6 7 77615 77725  15 3 24 24 49776 50248 3 3 45251 45251  16 3 25 25 87746 87750 9 9 68303 68303  17 2 5 10 238 9514 2 6 . .  18 3 33 33 17342 19654 7 8 0 0  19 3 16 36 71260 71338 2 3 71092 71285  20 3 17 29 24190 24190 4 4 20875 20875  21 3 18 28 13636 13930 5 5 . .  22 3 27 28 10013 10013 4 4 0 0  23 3 17 28 2587 44077 4 4 0 40892  24 3 23 23 394175 411460 5 6 376548 377059  25 3 15 15 17373 44577 4 7 12496 12496  26 3 7 7 8429 8429 6 6 . .  27 3 12 12 4188 10188 1 2 0 0  28 3 12 13 238878 239647 10 10 150239 158239  29 3 16 18 372954 397105 12 13 347834 348029  30 3 15 15 111032 128873 10 11 83803 83803 

24
 Table 11 - Variations in Negative Information among Credit Bureau Files 

 12:58 Wedn no. of minimun maximum minimun maximum  scores min no. max no. coll credit coll credit coll credit coll credit min  case avail. neg items neg items amt amt bal bal pub de 1 3 0 2 444 444 444 444 0  2 3 3 4 0 0 0 0 1  3 3 0 0 0 0 0 0 0  4 3 11 14 0 2684 0 2684 2  5 3 11 14 0 0 0 0 1  6 3 0 0 0 0 0 0 0  7 3 0 0 0 0 0 0 0  8 3 0 0 0 0 0 0 0  9 3 0 0 0 0 0 0 0  10 3 0 3 0 0 0 0 0  11 3 2 2 0 0 0 0 0  12 3 0 0 0 0 0 0 0  13 1 1 1 0 0 0 0 0  14 3 0 0 0 0 0 0 0  15 3 0 0 0 0 0 0 0  16 3 0 0 0 0 0 0 0  17 2 2 3 0 0 0 0 0  18 3 0 1 0 0 0 0 0  19 3 0 2 0 0 0 0 1  20 3 0 0 0 0 0 0 0  21 3 1 1 0 0 0 0 0  22 3 0 0 0 0 0 0 0  23 3 0 0 0 0 0 0 0  24 3 0 0 0 0 0 0 0  25 3 0 0 0 0 0 0 0  26 3 2 2 0 0 0 0 0  27 3 0 0 0 0 0 0 0  28 3 1 2 0 0 0 0 0  29 3 9 11 0 0 0 0 0  30 3 6 7 0 1560 0 269 0 

25
The first formal judgment of materiality occurred as information from the credit-report 

review was inserted into the SAS database. Two faculty researchers reviewed the 

summaries of information in the credit reports (Exhibit 7) and the interviewers’ notes and 

discussed questionable items with the interviewer before making a subjective judgment 

of whether the alleged errors would materially affect the credit scores. The next formal 

assessment occurred in the form of a recorded subjective assessment by the Fair Isaac 

researcher responsible for rescoring. The third formal assessment was accomplished by a 

simulated rescoring of the credit file in which the disputed items were changed and new 

credit scores were generated from the “frozen” credit record used to generate the initial 

scores. The fourth formal assessment of the materiality of the error was from the 

magnitude of the change in credit score that occurred after the outcomes from the formal 

dispute were determined. 

The first three formal materiality judgments all apply to alleged errors. The last applies 

to confirmed errors where the changes had been imposed and to alleged but not 

confirmed errors in instances where the bureaus and the consumers did not agree at the 

end of the dispute process. Note that a follow-up interview with the consumer should be 

refined to address instances when change in the credit report does not occur. The 

interview should determine the consumer’s understanding of why changes did not occur, 

which may include: the consumer files a dispute and is told that the bureau records are 

correct; the consumer files a dispute and receives no communication from the bureau in 

the matter; the consumer never files a dispute. 

Table 12 summarizes the outcomes for the seven consumers (23%) who planned to seek 

to have their credit records corrected. This included all instances where the faculty 

researchers judged that a material change could occur if corrections were applied to the 

credit files. The final outcome is classified as one of the following: 

1. resolved for consumer and material (RM) 

2. resolved for consumer and immaterial (RI) 

3. resolved for consumer and marginally material (RU) 

4. resolved for bureau (RB) 

5. unresolved and material (UM) 

6. unresolved and immaterial (UI) 

7. unresolved and marginally material or unknown (UU) 

8. outcome of dispute pending bureau response (DP) 

9. dispute not filed (NF) 

10. consumer alleges credit bureau did not respond to dispute registered (NR) 

11. item made irrelevant by circumstances (NA). 

The “unknown (UU)” category is necessary because, in some cases, it is hard to unravel 

the actual situation for an individual consumer who provides conflicting information. 

One consumer who initially alleged that the credit bureau reports contained errors 

softened his position during the follow-up survey. He had a large number of negative 

items and derogatory items in the records of each of the credit bureaus. In the follow-up 

26
survey, he indicated that he had not yet filed a dispute and, by the tone of the discussion, 

implied that he was unlikely to do so. He made a vague assertion that it was too hard to 

keep abreast of details and that he was inclined to accept the credit bureaus’ presentation 

of the information. That account was not rescored and the entry “NA” appears in 

corresponding cells of Table 12. 

In categorizing the impact of the tentative rescoring (stage 3), we treated any change in 

rescoring of less than 30 points (roughly the average inter-bureau range) as not material. 

We classified changes of 31-49 points as marginally material and changes of 50 points or 

more as material. We also considered whether the new score would move a consumer 

over a commonly used lending threshold. This judgment was made by a Fair Isaac expert 

who has worked with lenders on origination and account management strategies, 

including risk based pricing. In a larger study with more data available, we may want to 

modify these categories and could develop specific quantitative criteria for the 

assessment. 

Table 12 – Concordance in Materiality Assessments and Final Resolution 

Case Tentatively 

Judged 

Material 

Stage 1 

Tentatively

Judged 

Material 

Stage 2 

Tentative 

Material 

Score 

Change 

Material

Final 

Score 

Change 

All 

Tentative 

Judgments 

Agree 

Final 

Outcome

FTCR2GG YES YES YES YES YES RM 

FTCSP83 YES YES YES NA YES NF 

FTCFL58 NO NO NA NA YES NA 

FTCJMDI UNSURE UNSURE UNSURE NA YES NF 

FTCUNK1 NO NO NO NO YES NA 

FTC55GG UNSURE NA NA NA NA NA 

FTCBJX5 YES UNSURE NO NA NO NR 

FTCUIDG NO NO NO NA YES NF 

Implications for the Conduct of the National Study 

There are two vitally important findings from the pilot study. First, consumers can be 

engaged to conduct a thorough and effective review of their credit records via a telephone 

interview. Members of the research team and consumers themselves were unanimous in 

judging the review of information as thorough and objective. Second, effective 

mechanisms to protect consumers’ private information can be employed in the process. 

In the research protocols employed in the pilot study, participants were not required to 

reveal their SSNs to the university-based members of the research team and specific 

identifying information such as account numbers were suppressed in all information 

available to the university research associates. These restrictions did not hinder the 

quality of information produced. 

 

27
That said, the pilot study has identified two areas that pose particular challenges in the 

design of a national study. First, recruitment and engagement of participants to produce a 

sample representative of the universe of credit reports may require a variety of 

approaches. The approach used in the pilot was effective for reaching individuals with 

internet access. With sequential sampling, mailings can be adjusted to concentrate on 

segments of the population that are underrepresented as the study evolves. Spanishspeaking research associates could be engaged to reach individuals who do not speak 

English. For consumers without internet facility, alternative means of engagement would 

be required. Second, it will be critical to expand the follow-up interview procedures and 

protocols to determine the final outcome of any disputes filed and to determine why 

disputes are not filed when errors are alleged. 

Alternative Approaches to Constructing the Sample 

Our methodology relies on geo-demographic data and property-assessment information 

to produce a mailing list for building a representative sample of consumers. Ultimately, 

we wished to produce a representative sample of credit reports with approximately equal 

numbers in each of the five groups defined by credit-score quintiles. This could be 

accomplished more directly if the credit bureaus could provide the researchers with a file 

containing a unique identifier (a simple account sequence number – not the consumer’s 

SSN) for a designated fraction (e.g., 1 in 1000) of their active credit files along with the 

ZIP code, one other field for confirming cross-check, and possibly a few other pieces of 

information that affect the consumers’ credit scores. For example, the researchers could 

select the candidates for the study using a few key variables such as the number of 

negative items, number of public derogatories, number of active revolving accounts, total 

credit utilization and revolving credit utilization in a manner that would help to build a 

stratified sample consisting of consumers with different degrees of creditworthiness. The 

researchers could identify the consumers that they would like to try to engage and return 

the corresponding sequence numbers to the bureaus who, in turn, would provide current 

contact information to the researchers. The researchers could then invite the consumers 

to participate in the pilot study. 

Another possible route to the consumer is through referrals from trusted financial 

institutions as they deal with consumers’ applications for credit. The consumers could be 

informed that credit-bureau data were used as part of the application process and that the 

institution could offer, on behalf of the FTC, an opportunity to ensure that the credit 

decision was being made with the help of accurate data. Interested consumers would 

then “apply” to the research team to be part of the study. 

With either of these methods, participation can be arranged in a manner that does not 

require the consumer to divulge SSN to the researchers as long as the consumer had 

internet access. These methods could be used as a complement to the pilot-study 

recruiting methodology and would still retain arms-length objectivity in selecting 

participants (i.e., would not create questions of credit-bureaus’ selecting consumers 

whose records are unlikely to contain errors). A possible disadvantage of these 

28
alternatives, however, is the greater difficulty that would occur in managing the process 

with more participating parties. 

Protecting against “Phishing” Schemes by Imitators 

The pilot study reached only a few hundred consumers in the recruiting process and thus 

created de minimus risk of planting ideas for new “phishing” schemes like those 

undertaken in the names of financial institutions. Under such schemes unscrupulous 

individuals obtain personal information that enables them falsely to use the victims’ 

accounts or to steal the victims’ identities for acquiring credit. In a nationwide study, care 

must obviously be taken to avoid such risks. 

 Among the randomly selected participants in the pilot study was a deputy state attorney 

general who was initially very cautions about participating in the study. This person took 

pains to validate the study’s authenticity by checking the FTC website referenced in the 

recruiting letter and by visiting the UM-St. Louis website to check the background of 

members of the research team. Only after discussing the study with state legal staff and 

financial officials did the person agree to participate. The consensus among the state 

officials was that the protocols for this study were so complex and the verification 

mechanisms were so transparent that they could hardly have been conceived or 

implemented for “phishing” purposes. Streamlining the consent process to allow it to 

occur online and possibly enabling the acquisition of credit reports to flow directly from 

that transaction (as suggested earlier in this report) should therefore be done in a manner 

that would retain the face validity that seems to have accompanied the pilot study 

protocol. 

Data Security 

Special consideration must be given to protection of consumers’ confidential information 

and formal protocols were established for this purpose in the pilot study. In the course of 

the study, each participating institution and individual members of the research team took 

care to work in conformity with relevant data safeguards described in "Financial 

Institutions and Customer Data: Complying with the Safeguards Rule", extracted from 

http:/www.ftc.gov/bcp/conline/pubs/buspubs/safeguards.htm. Processes were approved 

by the university’s IRB committee. 

Each member of the research team was provided with detailed descriptions of the data 

that will be handled in the course of the study (including prototypical credit reports) and 

was trained to conform to the research protocols for protecting the consumer against the 

release or misuse of data. Access to information was limited to persons who had a need 

to see it. 

Information systems. Consumer data in hard-copy form were stored in a secured area 

(locked office and locked cabinet). Identifying information (consumer SSN and all but 

the last four digits of credit account numbers) were suppressed in hard copies of the 

credit reports that were mailed to the consumers and used by the researchers. A unique 

29
identifier was used as a cross-reference between consumer contact information (name, 

address and phone number) and information in the credit report. Electronic copies of 

consumer contact information were kept in separate computer files from those used to 

record data derived from reviews of the credit reports. We thus retained background 

information (such as name and address for contacting the consumer for the credit review) 

separately from the credit-report and demographic data. Password protection was used to 

limit access to computerized data. In the course of reviewing the credit files, extracts 

from the credit reports and consumers’ demographic data and reponses to inquiries from 

the follow-up questionnaire were placed in database for which the myFICO account 

number and consumer ZIP code were the only consumer identifiers. 

Upon receiving written notice from the FTC that lists of consumer contacts and crossreferences of consumer information with credit-report information are no longer needed, 

the research team will permanently delete the computer files that contain consumer 

names, addresses, etc. They will shred paper records with the consumer contact 

information. 

Effort and Costs of Conducting a National Study 

Checking the accuracy of credit-bureau information and studying the efficacy of the 

dispute-resolution process will inevitably require intensive involvement with a large 

sample of consumers. The effort required and incidental costs incurred at various stages 

of the pilot study can shed some light on the costs that would be incurred in the conduct 

of a national study that employs similar protocols. 

The pilot study involved the following activities with related costs: 

• Design and refinement of processes and instruments for recruitment of 

participants, authorizing access to credit-bureau information, preparing for indepth reviews of credit reports, conducting reviews of credit reports and 

summarizing results 

• Development of mailing lists using property assessment records and reverse 

online telephone directories (Purchasing mailing lists of homes with addresses 

and telephone numbers that meet specific estimated demographic criteria would 

be a likely alternative for a national study.) 

• Telephone recruitment with follow-up to secure written consent 

• Guiding participants in establishing myFICO accounts and purchasing credit 

reports 

• Production of credit reports (via myFICO.com), printing reports and mailing them 

to consumers with instructions (A streamlined process would be Implemented for 

a national study) 

• Preparation for the in-depth reviews of the credit reports 

• Conducting in-depth reviews in telephone interviews 

• Documenting results of reviews and examining them to judge materiality of errors 

• Following disputes 

30
• Rescoring credit reports to assess materiality of alleged errors (An automated 

process would be implemented for a national study) 

• Examining new credit reports to determine the results of disputes 

• Analyzing results 

• Documenting findings. 

For purposes of this report we shall focus on the variable costs of executing the unique 

features of the pilot study’s protocol. We shall exclude costs of developing and refining 

the processes and survey instruments to be employed, costs of developing/acquiring 

mailing lists (many commercial services are available for that task, for a fee), costs of 

designing and creating computer databases for the statistical extracts, costs of 

administrative overhead, and costs of conducting statistical analysis and preparing a final 

report. Some of these excluded items (e.g., development of survey instruments) have 

been initially addressed in the pilot study. Others would differ in nature depending on the 

scope of the national study. 

The variable costs of executing the study protocol will depend on the scale and intensity 

of work for the national study. They will also depend on the compensation of personnel. 

For human resources, we shall therefore estimate hours of personnel time required for 

various tasks based on times that were required for tasks unique to the pilot study. These 

time estimates are subdivided by type of personnel required to successfully execute the 

tasks. For example, in the pilot study the use of graduate research assistants and 

university office personnel was considerably less expensive (but equally effective) for 

some tasks than the time of the university principal investigators. Our time estimates are 

based on the assumption that 1000 consumers will undergo an in-depth review of their 

credit reports over a one-year period and follow-up for disputes will take place similarly 

to the pilot study. This allows for interruptions that may occur due to technical issues; 

leads and lags between recruiting, review of reports and dispute resolution; periodic 

pauses required to deal with problems that may arise; and suspension of consumercontact activities around holiday periods. 

In Table 13 we present the planning parameters that would drive the costs of executing 

the national study with the protocol that we employed in the pilot study. We used the 

yield rates and attrition rates that occurred in the pilot study except that we allowed for 

attrition of 10% after credit reports are drawn, with the expectation that the intensive 

follow-up that we used for the pilot study (including e-letters and calls from a university 

PI) would be replaced by a more extensive and less intensive strategy (i.e., by recruiting 

more into the pool and having RA’s do the follow-up). We allow for some anticipated 

efficiencies in the recruitment process from economies of scale. We also allow for 

efficiencies that can be garnered by having the study team members deliver the 

promotional codes to the participants instead of involving Fair Isaac in delivering them to 

the consumer. We have not accounted for additional streamlining that could be derived 

from the creation of dedicated websites created specially for a study or from allowing 

allow electronic (vs. paper-based) consent. Nor have we accounted for processes for 

consumers without internet access. 

31
Pct of mailings leading to contacts 68.90%

Pct of contacts interested 18.50% Contacts requd per credit review 9.2

Pct of interested engaged 65.00% Pct engaged/contact 12.0%

Attrition after engagement (pct) 10.00% Pct reviews/letter 8.3%

Pct who plan to file disputes 23.33%

Pct who do file disputes 13.33%

Pct of disputes with changes to bureau record 50.00%

Mins.to prepare and document mailing 4

No-answer calls per contact 5 Hours recruiting per contact 0.67

Mins. per no-answer call 5

Minutes for recruiting interview 15

Minutes for in-depth review 30

No-answer calls per in-depth review 4

Prelim calls per in-depth review 2

Minutes per prelim call 5

Mins to draw, document and mail report 30.00

Hours to prepare for in-depth review 1.50

Hours to conduct and document in-depth review 0.8

Mins. To contact consumer for follow-up 30

Mins. To conduct folllow-up 5

Batch size for drawing frozen reports 5

Hours to draw batch of reports from bureaus 1.75

Hrs per consumer to draw reports from bureaus 0.25

Hours to rescore each report 1.25

Table 13 - Planning Parameters

In Table 14, we show the resulting hours of effort under these assumptions. We also 

include the cost of purchasing the three bureau credit reports and credit scores at $50 per 

purchase. The numbers do, of course, change with changes in the planning parameters. 

The scenario presented excludes the costs of acquiring the initial mailing list, postage, 

long distance telephone charges, and computer supplies. Nor have we considered the 

costs of whatever publicity the FTC may wish to employ in the study. 

Note that in designing the national study, consideration should be given to weighting the 

outreach toward lower-income households. That will almost certainly result in changes 

to the planning parameters for that segment. Fewer consumers will have internet access; 

their credit reports may be more complicated; and disputes may be more frequent. We 

have, however, provided the framework within which these factors may be considered. 

Additional Recommendations 

The pilot study has demonstrated that consumers can be successfully engaged to conduct 

a thorough and effective review of their credit reports via a telephone interview. 

However, in the judgment of the research team, the FTC would be well advised to expand 

the pilot study to include another 120 consumers, thus giving a solid base of 150 

completed credit reviews for refining estimates of the parameters used to forecast the 

time and costs in a national study. The parameters would differ for consumers in 

different demographic segments and, with additional experience gained through an 

expanded pilot, the budgeting and planning for the national study can occur with greater 

precision. An extended pilot would allow experimentation with alternative methods of 

32
engaging consumers (including the impact of offering financial incentives for 

participation now that the novelty of obtaining free credit reports is diminishing), allow 

preliminary statistical analysis to be done on a nontrivial sample, and it would provide 

data that could be folded into the national study. It would also allow experimentation 

with processes that facilitate the filing of disputes, thereby increasing the number of 

consumers for which the final outcome can be determined. Expanding the pilot study 

would thus allow incremental progress to be made toward the completion of the national 

study and, at the same time, produce refinements that would improve the efficiency and 

efficacy of the national study. 

33
Table 14 - Resulting Activities, Personnel Hours and Costs of Purchasing Credit Repo

Activity Number Hours Required 

Univ Univ Univ 

RA Sup PI 

Consumers engaged 1,000Mailings required 13,410 894 179Contacts required 9,239 6,159 1,232

Sets of credit reports required 1,112 556 111 

In-depth interviews required 1,000 2,300 460

Prelim rescoring required 234 

Prelim rescoring batches 47 

Follow-up interviews required 1,000 583 117

Dispute filings expected to be intended 234Dispute filings expected to occur 134

Second reports expected to be needed 134 67 13 

Final rescorings expected to be needed 68 

Project direction and professional staff 

0 2,500 

Personnel hours for tasks and dollars for credit reports 10,560 2,112 2,500 

34
References 

Avery, Robert B., Paul S. Calem, Glenn B. Canner, and Raphael W. Bostic, “An 

Overview of Consumer Data and Credit Reporting”, Federal Reserve Bulletin, February 

2003, pp. 47-73. 

Barron, John M., and Michael E. Staten, “The Value of Comprehensive Credit Reports: 

Lessons from the U.S. Experience,” appearing in Credit Reporting Systems and the 

International Economy, edited by Margaret Miller, MIT Press, 2003. 

Consumer Federation of America, Credit Score Accuracy and Implications for 

Consumers, December 17, 2002. 

Furletti, Mark, “An Overview and History of Credit Reporting”, Discussion paper, 

Payment Cards Center, Federal Reserve Bank of Philadelphia, June, 2002. 

Hunt, Robert M., “The Development and Regulation of Consumer Credit Reporting in 

America”, Working Paper No. 01-21, Research Department, Federal Reserve Bank of 

Philadelphis, November 2002. 

Kabler, Brent, “Insurance-Based Credit Scores: Impact on Minority and Low Income 

Populations in Missouri”, Missouri Department of Insurance, January 2004. 

Miller, Michael M. and Richard A. Smith, “The Relationship of Credit-Based Insurance 

Scores to Private Passenger Automobile Insurance Loss Propensity”, An Actuarial 

Study by EPIC Actuaries, LLC, June 2003. 

Mortgage Credit Partnership Credit Scoring Committee, “Perspectives on Credit Scoring 

and Fair Mortgage Lending”, Perspectives, Five-Installment Series, Federal Reserve 

Bank of St. Louis, 2002. 

Staten, Michael E. and Fred H. Cate, “Does the Fair Credit Reporting Act Promote 

Accurate Credit Reporting?”, paper prepared for Building Assets, Building Credit: A 

Symposium on Financial Services in Low-Income Communities, Harvard University 

Joint Center for Housing Studies, November 18-19, 2003 

35
List of Exhibits 

Exhibit 1 – FTC Solicitation Letter 

Exhibit 2 – Consumer Consent Form 

Exhibit 3 – Follow-up Letter Sent from the University for 

 Recruitment 

Exhibit 4 – Screening Interview Guide with Demographic 

Questionnaire 

Exhibit 5 – Instructions for Establishing MYFICO Account 

Exhibit 6 – Checklist for consumer to Prepare for In-Depth Review 

 of Credit Reports 

Exhibit 7 – Sample Spreadsheet for Cross-Bureau Comparisons of 

 Key Elements in the Credit Reports 

Exhibit 8 – Interviewing Guide for In-Depth Review of Credit 

 Reports 

Exhibit 9 – Information Given to Consumers re Filing Disputes
Exhibit 1 – FTC Solicitation Letter 
(REDACTED)

This exhibit is available only upon request.

Contact:

Peter Vander Nat

Federal Trade Commission

Mail Drop NJ 4146

Washington, D.C. 20580
Exhibit 2 – Consumer Consent Form
(REDACTED)

This exhibit is available only upon request.

Contact:

Peter Vander Nat

Federal Trade Commission

Mail Drop NJ 4146

Washington, D.C. 20580
Exhibit 3 – Follow-up Letter Sent from the University for Recruitment
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 

April 24, 2006 

Dear Mr. ---------: 

You should recently have received a letter from Dr. Peter Vander Nat at the United States 

Federal Trade Commission in which Dr. Vander Nat indicated that your household was 

randomly selected for possible participation in a study on the accuracy of credit-bureau 

information. 

Over the next week or so, a research associate from the University of Missouri-St. Louis will 

be calling your home to invite you to be part of this important study. The research associate 

should be able to answer any questions you may have about the study and inform you about 

the mechanisms that we have established for you to obtain your credit reports and credit 

scores, should you decide to participate. 

We have arrangements with the Fair Isaac Corporation to provide promotional codes that you 

may use to establish an account (without charge) through which credit reports and 

corresponding credit scores from the three major credit bureaus may be viewed and printed. 

Participants also authorize the University to print a copy of the credit reports for review. 

Specific account numbers and social security numbers are suppressed in the reports for your 

protection. Our research associates will help you to understand the content of the reports and 

to check them for accuracy. They will also monitor the results of disputes that you register 

with the credit bureaus as a result of the review. 

I hope a member of your household does decide to participate in the study and that it is a 

valuable experience. You may leave a message for our research associates at (314) 516-5857 

if you would like to provide a number and time at which it would be most convenient for you 

to visit on the telephone. 

Sincerely, 

L. Douglas Smith, Ph.D. 

Professor and Director 
Exhibit 4 – Screening Interview Guide with Demographic 

Questionnaire
Screening Questions for FTC Pilot 

(revised 22 November 2005) 

Hello, my name is ______________. I am calling on behalf of the Georgetown University 

Credit Research Center and the Center for Business and Industrial Studies at the University 

of Missouri-St. Louis. We are conducting a study for the United States Federal Trade 

Commission on the accuracy of credit bureau information. You should have received a 

recent letter from the FTC indicating that your household was selected at random for this 

study and that we would be calling you. Do you have the package of materials from the FTC? 

First we must ask if you or a person in your immediate family works for a credit reporting 

agency such as Equifax, Experion or Trans Union. 

If yes, express thanks for taking the call but indicate that we are not permitted to 

include such households in the survey. 

The study applies to adults (age 21 or over) who have had some type of credit card, consumer 

loan or mortgage loan. Are there individuals in your household who are over 21 and with 

any type of credit card, car loan, home mortgage or other type of consumer loan in the past 

ten years? ______. 

If no one in the household meets these criteria, then express thanks, indicate that 

the household does not meet the criteria for the study and exit. 

We will be interviewing only one consumer in each household and are choosing the eligible 

person with the most recent birthday if that person is available. May we speak with that 

person? 

If same person, go to Informed Consent: 

If person with most recent birthday is a different person and not available, ask 

for person with next most recent birthday if available contact information and call 

back. 

For newly introduced eligible householder with most recent birthday: 

Hello, my name is ______________. I am calling on behalf of the Georgetown University 

Credit Research Center and the Center for Business and Industrial Studies at the University 

of Missouri-St. Louis. As we indicated to ____________, we are conducting a study for the 

United States Federal Trade Commission on the accuracy of credit bureau information. Do 

you have the package of materials from the FTC? _____ 

Qualification and Informed consent: 

Perhaps I should give you a bit of background for the study. 
Credit bureau information is used widely in granting credit, for setting loan rates and 

insurance premiums, and also by employers when making hiring decisions. This study will 

help the United States Federal Trade Commission (FTC) assess the extent to which 

consumers may be affected by erroneous credit-bureau data. It is necessary to survey 

individual consumers to obtain information needed for this important assessment. 

If you participate in the study, you will receive a free credit report and credit score from each 

of the three major credit bureaus. We will provide you with expert assistance to help you 

review and understand your credit report and credit score. You will be asked to identify and 

report any significant errors to the credit bureaus (with our help, if necessary). We will 

follow up to see if the requested changes were made to the credit-bureau files. All 

information collected and its use are protected and regulated by law. 

<In response to inquiries, it may be mentioned that to protect consumers, digits are removed 

from participants’ social security numbers and account numbers in all the credit reports to 

prevent anyone from misuse of the information. Credit card information does not include 

account statement details such as specific transactions or merchants with whom the customer 

did business. Nor does it contain information about household income or financial assets 

such as bank savings accounts, securities, etc.)

If subject is to be offered an honorarium add: Upon completion of this process, you will 

receive a $50 check for your participation. 

I must to ask you a few more questions to confirm that you qualify for participation in the 

study. 

 

Have you examined your own credit report from one or more credit bureau within the past 

year? 

If no, go to invitation to participate. 

Did you obtain your credit scores? ___ 

Did you find significant errors in the report? ___ 

If no, go to demographic information. 

Did you attempt to get the errors corrected? ___ 

If no, go to invitation to participate. 

Were the errors resolved to your satisfaction? ___ 

If yes, go to demographic information. 
Invitation to Participate: 

Your participation in this study will help our government test the accuracy of the credit 

reporting system. 

 

 If the person indicates that he or she wishes not to participate, go to demographic data to 

allow us to estimate refusal rates by demographic characteristic. 

May we confirm that your current address is: 

_[number]_, _[street]_, _[city]_, [state]_, _[zip]_.

And that your name is ______________________. 

Credit Report Acquisition 

We are required to obtain written consent before calling back to arrange the production and 

mailing of your credit reports and credit scores. Would you kindly sign the consent form 

provided in the FTC letter and mail it in the self-addressed envelope? When we receive your 

consent form, we shall call again to arrange the acquisition of your credit reports and credit 

scores. 

What is a good time for us to call back in the next couple of weeks? 

 Just to review the process, let me confirm that we will call back to telephone number 

_____________ at approximately (time) _____________on (date) 

_____________________ to arrange the acquisition of your credit reports. 

We have arrangements with the Fair Isaac Corporation to provide promotional codes that 

you may use to establish an account (without charge) through which credit reports and 

corresponding credit scores from the three major credit bureaus may be viewed and printed. 

Participants also authorize the University to print a copy of the credit reports for review. If 

you have internet access, you may establish the account using a password that we provide. 

That way, you will not have to give your SSN to the university over the phone. If you do not 

have internet access, we can establish the account for you during the telephone visit. Either 

way, we are willing to print the long credit reports (which can amount to 150 pages (50 pages 

per bureau) for people with a long credit history) and mail you a copy. 

We shall furnish you with a guide for organizing the information in preparation for an indepth telephone interview in which we help you study them in detail and identify any 

discrepancies. That interview could take from 10 minutes to an hour, depending on 

complexity of the reports and whether there seem to be errors. 
Demographic Information: 

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___, high school, some college___, associates degree _____, 

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? ___ 

Q1. Is your total annual household income $50,000 or more? ___ If no, go to Q1c: 

 Q1a. Is it over $75,000? ___ If yes, go to Q1b 

 Q1b. Is it over $100,000 ? ____ 

Q1c. Is your total household income less than $25,000? ___ 

Do you own____, or rent____ your living quarters? 

Are there any children under the age of 18 living in the household? ___________If yes, how 

many? ____ 
Thank you very much. 

If person has consented to participate, say we are planning to call you on ____________. 

At that time, we will acquire your credit report and arrange a time to review it with 

you. 

Are there any further questions that I might answer at this time? Give the RA office 

telephone number (314) 516-5857 for any questions that may arise in the meantime. 
Exhibit 5 – Instructions for Establishing MYFICO Account
Procedure for Establishing Fair Isaac Account 

On-line for FTC Study on Credit-Bureau Accuracy 

The following instructions are for establishing your account with Fair Isaac. In the initial 

session, you will furnish your personal information such as SSN and address to associate the 

account with your record. Once the account is established, it is accessed using the logon 

ID and password without requiring your SSN. The university will then use the logon ID 

and password to print the credit report and send the same to you. Please note that, while the 

price for the service is identified as you establish the account, you should stop after opening 

the account and before making the purchase. 

Please be sure to use the logon ID and password that the university provided for you. 

I. Click on the following website address: 

http://www.myfico.com/

II. The following web page will appear: 
To get your credit Report and credit scores from all the three credit rating agencies, please 

click on the order sign besides $44.85 pointed with a yellow arrow below. 

Once you click on the “order” Sign besides $ 44.85, it will take you to the page below: 

Click here 

1. Click here 

2. Click here next 

Please select the One –time Purchase option of $44.85 and continue by clicking on the “Buy” 

button the screen. 
NOTE: You should stop short of making payment at the end even though you are choosing a 

product with a price attached. Fair Isaac Corporation will send you the promotional code and 

you will use the promotional code to purchase the credit reports. 

The next page will ask you for a promotional code. You don’t enter any code; instead 

continue by clicking on the “Continue” button displayed on the screen, as indicated by the 

arrow sign below. 

Click here 

Once you click on Continue, the next page is where you will provide details to set up your 

account. The setting up of the account requires: 

Personal Information 

Account Set Up 

Contact Preference 

User Agreement 
Please provide all the information that is mandatory which is indicated with a red color 

dot. 

Personal Information

Account Set Up 
Contact preference 

User Agreement 
Tick here 

Tick here 

Click here 

Once you click on “Continue”, the following page will appear, requesting you for payment 

details. Please DO NOT furnish any payment information or details. Instead exit from this 

page by clicking at the red box indicated by the arrow sign. 
Logging in your account: 

Once you exit from the page above. Log back in to http://www.myfico.com/ to verify that 

your account has been accurately set up and activated. Login using the Login ID and 

password that we provided by clicking on to LOG IN; indicated with the arrow sign below. 

Click here 

Please enter the Login ID and Password that was provided and then click on the blue “Log in 

Button” 
Click here 

Once you have been able to successfully log on to your account you will see your name 

appear in the two places circled in red. 

Congratulation your account has been successfully set up with Fair Isaac!!! 

Once you have successfully established your account on myfico.com, please send a 

confirmation email to busresc2@umsl.edu. On receipt of the confirmation email, we 

shall have Fair Isaac Corporation email the promotional code to you. 

If you have any troubles establishing you account on the internet, you could call The Center 

for Business and Industrial studies at the University of Missouri -St Louis at 314-516-5857

and we would be happy to help you set up your account. 
If you inadvertently make an error, please contact the university at (314) 516-5857 to 

give us the actual logon ID and password that you used. 
Exhibit 6 – 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? 
Exhibit 7 – Sample Spreadsheet for Cross-Bureau Comparisons of 

Key Elements in the Credit Reports 
Name / ID : ------- 

Start Time: End Time: 

Particulars A B C 

Date of Birth 

November xx, 

19xx, semisuppressed 

November xx, 

19xx, semisuppressed suppressed 

Score XXX XXX XXX 

Name: 

Present ABC ABC ABC 

Previous 

Address: 

Present 

Previous 

Employment History 

No. of accounts 27 27 16 

No of accounts with zero 

balances 16 16 6 

No. of accounts with Balances 11 11 10 

No. of credit inquries for 

applying for credit 3 0 1 

Total amount of available 

credit 112061 111966 111032 

Total Balances/Credit 

Utilization 112018 112211 209914 

Percentage of credit Utilization 

(%) 99.96% 100.22% 189.06% 

Amount of available credit on 

CC & revolving account 1151 1126 1126 

Balances/Credit Utilization on 

CC & revolving account 681 681 681 

Percentage of credit Utilization 

(%) 59.17% 60.48% 60.48% 

Length of credit history 15 Years, 5 

Months 

15 Years, 5 

Months 

15 Years, 5 

Months 

Negative Items: 2 2 2 
Nelnet LNS- 120 

days past due 

Nelnet LNS- 120 

days past due 

Nelnet LNS120 days 

past due 

Capital 1 Bk- 120 

days past due 

Capital 1 Bk120 days past 

due 

Capital 1 Bk120 days 

past due 

Collection #1 

Collection 

agency: 

Kannennsohn 

None None 

Original Creditor: 

Med1 Hunility of 

Mary Health 

Partners 

Date Assigned: 

Not on record 

Date Reported: 

July 2001 

Amount: $ 269 ; 

Balance: $ 269 

Date paid out: Not 

on record 

Date Closed: Not 

on record 

Risk Rate (%) 31.00% 31.00% 31.00% 

Mortgage information: 

Open: 

First Place 88000 88000 88000 

88000 88000 88000 

Closed: 

First Place 75660 75660 

Transferred: 

Home Improvement 
Other Loan 

Open: 

0 0 0 

Closed/Deferred: 

Auto Loan 

Open: 

0 0 0 

Closed: 

Transferred: 

Installment A/C 

Open: 

STRBKTR/GLHE- Student Loan 10700 10700 10700 

Salmae/ Glhec 7560 7560 7560 

Doy Fed C U 1250 1250 

19510 19510 10700 

Transferred: 

EFS Finance 2625 2625 2625 

EFS Finance 2625 2625 2625 

Closed: 

Doy Fed C U 1500 1500 

Firstplace 10726 10726 0 

717 Cr UN 3841 3841 

Amer Gen Fin 501 501 501 

East Trumbul 4346 

Credit Card - Revolving 

account- Open 

Capital 1 Bk 551 551 551 

Sunoco/ Citi 600 575 575 

1151 1126 1126 
Credit Card - Revolving 

account- Closed/ Lost or stolen 

Capital 1 Bk 1014 1014 1014 

Credit Card - Revolving 

account- Transferred 

Revolving account- charge 

account 

Open: 

CBUSASEARS 500 530 530 

Gemb/ Sams 1000 950 950 

Gemb/ Lowes 1900 1850 1850 

3400 3330 3330 

Closed: 

Gemb/ Dillards 298 298 

Citifinancia 2500 2500 2500 

Transferred: 
Exhibit 8 – Interviewing Guide for In-Depth Review of Credit 

Reports 
Interview Format for Credit Report Reviews with Households 

 

Header information

First, have you had any recent changes in your name, address, or job that is not reflected in your 

(TransUnion/Experian/Equifax) credit report? 

 yes (specify) 

 no 

Your (TransUnion/Experian/Equifax) credit report lists your name as (name). Is (name) the name you 

currently use for your credit accounts. 

 yes 

 no 

Is your name spelled correctly? 

 yes 

 no 

The credit report also lists other names. Read names. Have you used these names for credit accounts 

in the past? 

 yes 

 no 

Have you used any other names for credit accounts during the last seven years? 

 yes 

 no 

What names have you used? 

Is your current address (address)? 

 yes 

 no 

The credit report also lists previous addresses. Read addresses. Have you previously lived at these 

addresses? 

 yes 

 no 

Have you had any other previous addresses in the past seven years? 

 yes 

 no 

How many previous addresses have you had in the past seven years? 

 number _____ 

 don’t know 

 refused 

 

Is (employer name) your current employer? 

 yes 

 no 

Is (year) the year of your birth? 

 yes 

 no 

To make this review of your credit report as easy as possible for you, we would like to start with 

identifying the forms of credit you are currently using. Please feel free to refer to any other documents or 

files you may have in your house that may assist you in providing us with accurate information on your 

credit relationships. 
Mortgages 

Prior to phone call, interviewer prepares a list of mortgages extracted in credit report.

 R has outstanding mortgages shown in credit file go to Q3 

 R does not have outstanding mortgages in credit file go to Q1 

1. In the screening interview you said that you (own/rent) your home. Is this correct? 

 R owns go to Q2 

 R rents go to Q7 

2. Do you currently owe mortgage debt? 

 yes go to Q5 

 no go to Q7 

3. Your (TransUnion/Experian/Equifax) credit report shows (number) mortgages with outstanding 

balances, including second mortgages and home equity loans or lines of credit. A (amount) current 

balance with (lender), and ... [read additional mortgages.] 

4. Do you have any (other) mortgages with outstanding balances? 

 yes go to Q5 

 no go to Q6 

5. Is the mortgage debt you owe listed anywhere on your (TransUnion/Experian/ Equifax) credit report? 

 yes Ask Q5a. 

no Go to Q7. 

 

a. Which loan is your mortgage debt? (Write in lender’s name.) 

 Are there any other mortgage debts listed in this credit 

report?

b. Does the balance on (date) look about right? 

 If “no,” ask - What is the problem?

c. The credit report shows that the account (was xx days/was not) past 

due on (reporting date). Is this correct? 

If “no,” ask - What was the status of the account?

d. The credit report shows that the account was (number) times past 

due in the last 6 months. Is this correct? 

If “no,” ask - Were there fewer delinquencies or more delinquencies 

than (number) in the last 6 months?

6. We would like to ask a few questions about outstanding mortgages not included in the credit report. 

 What was the ... 

 

a. lender’s name?

b. the date the mortgage was taken out?

c. the monthly payment?

d. the original amount taken out?

e. the current amount outstanding? 

R has closed mortgages go to Q7 
R does not have closed mortgages go to Q8 

7. Your (TransUnion/Experian/Equifax) credit report shows (number) mortgages that have been 

closed. A mortgage with (lender), and ... [List additional mortgages.] 

Record information from credit report prior to interview.

 Lender name 

 Date closed 

Loan status at closing 

a. Is the loan with (lender) closed? 

b. The credit report shows that the account was (current/xx days past due) at the time of closing. Is 

this correct? 

If foreclosure or charge off, ask 

c. The credit report shows that the loan was (foreclosed/charged off). Is that correct? 

 

Auto loans 

Prior to phone call, interviewer prepares a list of current auto loans extracted from the credit reports. 

R currently owes auto debt go to Q8 

R does not currently owe auto debt go to Q9 

8. Your (TransUnion/Experian/Equifax) credit report shows (number) auto loans with outstanding 

balances. A (amount) balance with (lender), and ... [List additional auto loans.] 

Record information from credit report prior to interview.

 Lender name 

 Current balance 

 Original balance 

 Date opened 

 Monthly payment 

 Delinquent or reporting date 

 Currently delinquent (indicate duration) 

 Times past due in last 6 months

For each loan listed in the credit report, ask:

a. Do you currently have a loan with(lender)? 

If “no,” ask - Have you never had a loan with (lender), or has the loan 

been closed?

b. Does the balance on (date) look about right? 

 If “no,” ask - What is the problem? 

c. The credit report shows that the account (was xx 

 days/was not) past due on (reporting date). Is this correct? 

If “no,” ask - What was the status of the account?

9. Do you have any (other) auto loans with outstanding balances? 

 yes go to Q10 

 no go to Q12 

10. Is the auto loan you owe listed anywhere on your (TransUnion/Experian/ Equifax) credit report? 

yes go to Q10a 

 no go to Q11 
a. Which loan is your auto debt? 

 (Write in lender’s name.) 

 Are there any other auto loans listed in this credit report?

b. Does the balance on (date) look about right? 

 If “no,” ask - What is the problem?

c. The credit report shows that the account (was xx 

 days/was not) past due on (reporting date). Is this correct? 

If “no,” ask - What was the status of the account?

d. The credit report shows that the account was (number) times past 

due in the last 6 months. Is this correct? 

If “no,” ask - Were there fewer delinquencies or more delinquencies 

than (number) in the last 6 months?

11. We would like to ask a few questions about outstanding auto loans not included in the credit report. 

 What was the ... 

 

a. lender’s name?

b. the date the loan was taken out?

c. the monthly payment?

d. the original amount taken out?

e. the current amount outstanding?

R has closed auto loans go to Q12 

R does not have closed loans go to Q13 

12. Your (TransUnion/Experian/Equifax) credit report shows (number) auto loans that have been closed. 

A loan with lender X, and ... [list additional likely car loans.] Is this correct? 

Record information from credit report prior to interview.

 Lender name 

 Date closed 

 Loan status at closing

a. Is the loan with (lender) closed?

b. The credit report shows that the account was (current/xx days past due) 

at the time of closing. Is this correct?

If reposession or charge off, ask 

c. The credit report shows that the (auto was repossessed /loan was 

charged off). Is that correct?

Other closed-end instalment loans 

Prior to phone call, interviewer prepares a list of other outstanding closed-end instalment loans extracted 

from the credit reports. 

R currently owes other instalment debt go to Q13 

R does not currently owe auto debt go to Q14 
13. Your (TransUnion/Experian/Equifax) credit report shows (number) other loans with regular monthly 

payments with outstanding balances. A (amount) balance with (lender), and ... [List additional other 

closed-end instalment loans.] 

Record information from credit report prior to interview.

 Lender name 

 Current balance 

 Original balance 

 Date opened 

 Monthly payment 

 Delinquent on reporting date 

 Currently delinquent (indicate duration) 

 Times past due in last 6 months

For each loan listed in the credit report, ask:

a. Do you currently have a loan with(lender)? 

If “no,” ask- Have you never had a loan with (lender), or has the loan been 

closed? 

b. Does the balance on (date) look about right? 

 

If “no,” ask - What is the problem?

c. The credit report shows that the account (was xx 

 days/was not) past due on (reporting date). Is this correct? 

If “no,” ask - What was the status of the account?

14. Do you have any (other) loans with regular payments with outstanding balances? 

 yes go to Q15 

 no go to Q16 

15. Is the loan you owe listed anywhere on your (TransUnion/Experian/ Equifax) credit report? 

yes go to Q15a 

 no go to Q16 
15a. Which loan is it? 

 (Write in lender’s name.) 

 Are there any other loans listed in this credit report?

b. Does the balance on (date) look about right? 

 

If “no,” ask - What is the problem?

c. The credit report shows that the account (was xx 

 days/was not) past due on (reporting date). Is this 

correct? 

If “no,” ask - What was the status of the account?

d. The credit report shows that the account was (number) times 

past due in the last 6 months. Is this correct? 

If “no,” ask - Were there fewer delinquencies or more delinquencies 

than (number) in the last 6 months?

16. We would like to ask a few questions about other outstanding regular payment loans not included in 

the credit report. 

 What was the ... 

a. lender’s name?

b. the date the loan was taken out?

c. the monthly payment?

d. the original amount taken out?

e. the current amount 

outstanding?

R has closed other closed-end installment loans go to Q17 

R does not have closed other closed-end installment loans go to Q18 

17. Your (TransUnion/Experian/Equifax) credit report shows (number) regular payment loans that have 

been closed. A loan with (lender), and ... [List additional closed-end installment loans.] 

Record information from credit report prior to interview.

 Lender name 

 Date closed 

 Loan status at closing

a. Is the loan with (lender) closed?

b. The credit report shows that the account was (current/xx days past 

due) at the time of closing. Is this correct?
Credit cards 

Prior to phone call, interviewer prepares a list of current credit cards extracted from the credit report. 

R has credit cards with outstanding balance go to Q18 

R does not have credit cards with outstanding balance go to Q19 

18. Your (TransUnion/Experian/Equifax) credit report shows (number) credit card accounts with 

outstanding balances reported. A $xxx,xxx balance with lender 1, and ... [List additional credit 

cards as a separate attachment.] 

Record information from credit report prior to interview.

 Lender name 

 Credit limit 

 Current balance 

 Past due on reporting date (indicate duration) 

 Times past due in last 6 months

Does the balance owed at (date) look about right?

The credit report shows that the account (was/was not) past due on (date). 

Is this correct?

The credit report shows that the account was x times past due in the past xx 

months. Is this correct?

R has open credit card accounts that were reported in the last 12 months go to Q19 

R does not have open credit card accounts that were reported in the last 12 months go to Q20. 

19. Your (TransUnion/Experian/Equifax) credit report shows (number) of other credit card accounts that 

have been reported to the credit bureau in the last 12 months. A credit card with (lender), and ... [List 

additional credit card accounts.] 

Record information from credit report prior to interview.

 Lender name 

 Credit limit 

 Past due on reporting date (indicate duration) 

 Times past due in last 6 months

The credit report shows that the account (was/was not) past due on (date). 

Is this correct?

The credit report shows that the account was x times past due in the past xx 

months. Is this correct?

 

 

20. Your (TransUnion/Experian/Equifax) credit report shows (number) credit cards that have been closed. 

A loan with lender X, and ... [list additional cards as an attachment.] Is this correct? 

Issuer names

Was this card paid off?

The credit report shows that the account was past due at the time of closing. 

Is this correct?

If charged off: The credit report shows that the card was charged off). Is 

that correct? 

 

Credit inquiries
21. Your credit report shows (number) of requests by lenders to review your credit history in connection 

with a loan application. 

Record information from credit report prior to interview 

 Lender name 

 Date of inquiry

a. Did you apply for a loan at (lender) in (month, year)?

Collections

 22. Your credit report shows (number) of collection items. 

Record information from credit report prior to interview 

 Collection agency 

 Original creditor 

 Original amount 

 Balance 

 Date of last report

a. Were you contacted by a collection agency about a balance 

that (creditor) claimed you owed?

b. The credit report indicates that (the claim was paid/xx is still 

owed). Is that correct? 

If “no” in Q22b, ask

c. What is the not correct? (specify)

Check for possible duplications in items and review with 

respondent.

 

Public records

23. Your credit report shows (number) of public record items. 

Record information from credit report prior to interview 

 Type of public record 

 Date filed 

 Plaintiff 

 Claim amount 

 Resolution 

 Date resolved

a. Did you have a (type) on (month/year)?

b. Ask whether the item was resolved as indicated.

If “no” in Q22b, ask -

c. What is the not correct? (specify)

Check for possible duplications in items and review with 

respondent.

Is there any thing else in your credit reports that you would like to discuss? 
Exhibit 9 – Information Given to Consumers re Filing Disputes
Correcting Inaccuracies in Credit-Bureau Files 

At the bottom of the three credit-bureau reports is information about the process to follow if you 

identify inaccuracies. Specifically, you will find the following addresses and phone numbers 

through which you should report inaccuracies to the respective credit bureaus. In addition, you 

should bring an error to the attention of the creditor that seems to have furnished the inaccurate 

information to the credit bureau. To register disputes regarding information obtained through 

myFICO, Fair Isaac recommends that you follow the instructions located at the bottom of the 

individual reports. Each bureau offers different options as follows: 

 

Equifax (phone, mail)

 

Phone: 1-866-238-8067 

Mail: 

Equifax Disputes 

P.O. Box 740256 

Atlanta, GA 30374-0256 

TransUnion (phone, mail, online) 

Phone: 1-800-916-8800 

Mail:

TransUnion Disputes 

2 Baldwin Place, P.O. BOX 1000 

Chester, PA 19022 

Online:

TransUnion Disputes (You will be required to provide your File Identification Number (FIN)

along with your dispute information. This number is located at the bottom of your myFICO 

TransUnion credit report.) 

Experian (online) 

Online:

Experian Disputes (You will be required to provide your Report ID number along with your 

dispute information. This number is located at the bottom of your myFICO Experian credit 

report.) 

FTC Information 

Additional information on registering disputes regarding information in credit-bureau files can 

be found at the FTC website: 

http://www.ftc.gov/bcp/conline/pubs/credit/freereports.htm 

Included in the FTC information are answers to the following questions: 

Q: What if I find inaccuracies or incomplete information in my credit report? 
A: Under the FCRA, both the consumer reporting company and the information provider (that is, 

the person, company, or organization that provides information about you to a consumer 

reporting company) are responsible for correcting inaccurate or incomplete information in your 

report. To take full advantage of your rights under this law, contact the consumer reporting 

company and the information provider. 

1. Tell the consumer reporting company, in writing, what information you think is inaccurate. 

Consumer reporting companies must investigate the items in question - usually within 30 days - 

unless they consider your dispute frivolous. They also must forward all the relevant data you 

provide about the inaccuracy to the organization that provided the information. After the 

information provider receives notice of a dispute from the consumer reporting company, it must 

investigate, review the relevant information, and report the results back to the consumer 

reporting company. If the information provider finds the disputed information is inaccurate, it 

must notify all three nationwide consumer reporting companies so they can correct the 

information in your file. 

When the investigation is complete, the consumer reporting company must give you the written 

results and a free copy of your report if the dispute results in a change. (This free report does not 

count as your annual free report under the FACT Act.) If an item is changed or deleted, the 

consumer reporting company cannot put the disputed information back in your file unless the 

information provider verifies that it is accurate and complete. The consumer reporting company 

also must send you written notice that includes the name, address, and phone number of the 

information provider. 

2. Tell the creditor or other information provider in writing that you dispute an item. Many 

providers specify an address for disputes. If the provider reports the item to a consumer reporting 

company, it must include a notice of your dispute. And if you are correct - that is, if the 

information is found to be inaccurate - the information provider may not report it again. 

Q: What can I do if the consumer reporting company or information provider won't correct the 

information I dispute? 

A: If an investigation doesn't resolve your dispute with the consumer reporting company, you 

can ask that a statement of the dispute be included in your file and in future reports. You also can 

ask the consumer reporting company to provide your statement to anyone who received a copy 

of your report in the recent past. You can expect to pay a fee for this service. If you tell the 

information provider that you dispute an item, a notice of your dispute must be included any time 

the information provider reports the item to a consumer reporting company. 
Exhibit 10 – Contents of SAS Database Created to Summarize CreditBureau Information and Outcomes for Each Participant 
 Contents of SAS Dataset with Summary Information for Each Case 

 18:48 Wedn The CONTENTS Procedure  Data Set Name: CREDREP.SURVEY Observations: 30  Member Type: DATA Variables: 94  Engine: V8 Indexes: 0  Created: 12:04 Tuesday, June 13, 2006 Observation Length: 656  Last Modified: 14:42 Tuesday, June 13, 2006 Deleted Observations: 0  Protection: Compressed: NO  Data Set Type: Sorted: NO  Label:  -----Engine/Host Dependent Information-----  Data Set Page Size: 57344  Number of Data Set Pages: 1  First Data Page: 1  Max Obs per Page: 87  Obs in First Data Page: 30  Number of Data Set Repairs: 0  File Name: /accounts/faculty/ldsmith/credrep/survey.sas7bdat  Release Created: 8.0101M0  Host Created: SunOS  Inode Number: 7884188  Access Permission: rw-r--r--  Owner Name: ldsmith  File Size (bytes): 65536  -----Alphabetic List of Variables and Attributes-----  # Variable Type Len Pos Label  -----------------------------------------------------------------------------------  63 amtcollerr Num 8 352 amt. error/in coll./reported  46 amtmtgebalerr Num 8 240 amt. error/in mtge.bal.  54 amtrevbalerr Num 8 296 amt. error/rev. credit/balance  88 bureauchangeA Char 1 608 correction/made/Bureau A  89 bureauchangeB Char 1 609 correction/made/Bureau B  90 bureauchangeC Char 1 610 correction/made/Bureau C  79 checklisthelp Char 1 454 found/checklist/helpful  59 collamtA Num 8 328 amt. sent/to coll./Bureau A  60 collamtB Num 8 336 amt. sent/to coll./Bureau B  61 collamtC Num 8 344 amt. sent/to coll./Bureau C  64 collbalA Num 8 360 bal. on/coll./Bureau A  65 collbalB Num 8 368 bal. on/coll./Bureau B  66 collbalC Num 8 376 bal. on/coll./Bureau C  62 collecterr Char 1 443 error in/amt. sent/to coll. 
 Contents of SAS Dataset with Summary Information for Each Case 

 18:48 Wedn The CONTENTS Procedure  -----Alphabetic List of Variables and Attributes-----  # Variable Type Len Pos Label  -----------------------------------------------------------------------------------  42 curmtgbalA Num 8 216 total/mtge. bal./Bureau A  43 curmtgbalB Num 8 224 total/mtge. bal./Bureau B  44 curmtgbalC Num 8 232 total/mtge. bal./Bureau C  9 curraddOK Char 1 431 current/address/OK  5 dateofbirth Char 8 423 date of/birth  85 disputeA Char 1 605 disputed/item/Bureau A  86 disputeB Char 1 606 disputed/item/Bureau B  87 disputeC Char 1 607 disputed/item/Bureau C  91 disputecomment Char 40 611 dispute/info  92 disputefiled Char 1 651 dispute/filed  93 disputevalidated Char 1 652 dispute/validated  69 educlevel Char 1 446 educ/category  11 employhistok Char 1 433 employment/history/OK  71 employstatus Char 1 448 employ./category *  84 errtext Char 147 458 descriptive/summary  94 filescorrected Char 1 653 files/corrected  4 gender Char 1 422  36 histyymmA Num 8 168 credit/hist. yymm/Bureau A  37 histyymmB Num 8 176 credit/hist. yymm/Bureau B  38 histyymmC Num 8 184 credit/hist. yymm/Bureau C  73 homeeowner Char 1 450 owns/home  1 id Char 7 408 subject/id  72 incomegroup Char 1 449 income/group  32 inquiriesA Num 8 144 inquiries for/new credit/Bureau A  33 inquiriesB Num 8 152 inquiries for/new credit/Bureau B  34 inquiriesC Num 8 160 inquiries for/new credit/Bureau C  35 inquirieserr Char 1 439 wrong/credit/inquiries/  80 intervmins Num 8 400 mins./spent in/tel. review  74 kidsunder18 Num 8 384 no. children/under 18  68 maritalstatus Char 1 445 marital/cateegory  82 materialerr Char 1 456 errors/judged/material  45 mtgebalerr Char 1 440 error in/mtge.bal.  39 mxmtgeA Num 8 192 total/mtge. amt./Bureau A  40 mxmtgeB Num 8 200 total/mtge. amt./Bureau B  41 mxmtgeC Num 8 208 total/mtge. amt./Bureau C  20 negitemsA Num 8 72 negative/items/Bureau A  21 negitemsB Num 8 80 negative/items/Bureau B  22 negitemsC Num 8 88 negative/items/Bureau C  23 negitemserr Char 1 436 error in/no. of neg/items  19 nonzeroerr Char 1 435 error in/nonzero/balances  12 numaccA Num 8 24 active/accounts/Bureau A 
 Contents of SAS Dataset with Summary Information for Each Case 

 18:48 Wedn The CONTENTS Procedure  -----Alphabetic List of Variables and Attributes-----  # Variable Type Len Pos Label  -----------------------------------------------------------------------------------  13 numaccB Num 8 32 active/accounts/Bureau B  14 numaccC Num 8 40 active/accounts/Bureau C  15 numaccerr Char 1 434 invalid/account(s)/reported  56 numcollA Num 8 304 no. of/coll. actions/Bureau A  57 numcollB Num 8 312 no. of/coll. actions/Bureau B  58 numcollC Num 8 320 no. of/coll. actions/bureau C  16 numnonzeroA Num 8 48 nonzero/balances/Bureau A  17 numnonzeroB Num 8 56 nonzero/balances/Bureau B  18 numnonzeroC Num 8 64 nonzero/balances/Bureau C  70 occup Char 1 447 occup/category  83 plandispute Char 1 457 plans to/register/dispute  78 prepmins Num 8 392 mins./spent/preparing  10 prevaddOK Char 1 432 previous/addresses/OK  24 pubderogA Num 8 96 no. of/public derogs./Bureau A  25 pubderogB Num 8 104 no. of/public derogs./Bureau B  26 pubderogC Num 8 112 no. of/public derogs./Bureau C  27 pubderogerr Char 1 437 error in/no. of/public derogs.  67 race Char 1 444 race cat.  76 recallinaccuracies Char 1 452 recalls/signif./inacurracies  77 registereddispute Char 1 453 registered/dispute  50 revbalA Num 8 272 rev. credit/balance/Bureau A  51 revbalB Num 8 280 rev. credit/balance/Bureau B  52 revbalC Num 8 288 rev. credit/balance/Bureau C  53 revbalerr Char 1 441 error in/rev. credit/balance  47 revlimA Num 8 248 rev. credit/limit/Bureau A  48 revlimB Num 8 256 rev. credit/limit/Bureau B  49 revlimC Num 8 264 rev. credit/limit/Bureau C  55 revutilerr Char 1 442 error in/credit/utiliz.  75 satisfiedprocess Char 1 451 satisfied/with/review  6 scoreA Num 8 0 Bureau A/credit/score  7 scoreB Num 8 8 Bureau B/credit/score  8 scoreC Num 8 16 Bureau C/credit/score  2 state Char 2 415  81 thoroughreview Char 1 455 found/review/thorough  28 totbalA Num 8 120 total acc./balances/Bureau A  29 totbalB Num 8 128 total acc./balances/Bureau B  30 totbalC Num 8 136 total acc./balances/Bureau C  31 totbalerr Char 1 438 invalid/acc.balance/reported  3 zipcode Char 5 417 ZIP/code 
Exhibit 11 – Follow-up E-Letters to Re-engage Participants and 

Inquire if Disputes had been Filed 
Follow-up E-letter Sent to Agreed Participants from whom Consent Form was Due 

Dear (name of potential) 

I am writing with follow-up on your possible participation in the FTC pilot study regarding the 

accuracy of credit bureau records.

Aarti Dinesh, our graduate research associate, has informed me that you expressed interest in 

participating in the study but that she has not yet received the confirmatory signed consent form 

that we must have in hand before working with you to draw the credit reports with your current 

credit scores.

Once that occurs, we give you specific instructions for establishing an account with Fair Isaac 

through which the credit reports and scores are obtained. After your account is established, you 

may review the material on-line for about a month (using the login ID and password that we 

provide) and the university can print the voluminous reports and send them to you for an in-depth 

review. Digits in your SSN and in the account numbers are suppressed in the reports to prevent 

any possible misuse of the information. 

We send instructional material for reviewing the credit reports in preparation for an in-depth 

telephone interview in which we identify potential errors. If you find errors, we shall inform you 

whether they are likely to have had an adverse affect on any of your credit scores and, if so, how 

to proceed to get the errors corrected. Finally, we would arrange for you to draw new credit 

reports (without charge and after a suitable time) and determine if promised corrections have 

actually been applied to the credit-bureau files.

We are completing this phase of the study over the next two weeks. If you are still interested in 

participating, would you kindly get in touch with us so that we may complete the arrangements for 

you. The e-mail address for our research associates is busresc2@umsl.edu and the telephone 

number is (314) 516-5857.

We do appreciate your expressed interest in participating in this important study and trust that it 

will be a valuable exercise for you.

Sincerely, 
Follow-up E-letter Sent to Participants Needing to Purchase Credit Reports 

Dear (participant with promo code) 

I am writing with follow-up on your participation in the FTC pilot study regarding the accuracy of 

credit bureau records. 

The promotional code that has been furnished to you (through e-mail from the Fair Isaac 

Corporation) is the mechanism that we use to establish accounts in a way that prevents study 

participants’ having to divulge their SSN’s to anyone on the research team. Once your account is 

established, you may review the material on-line for about a month and the university can print 

the voluminous reports and send them to you for an in-depth review. Digits in your SSN and in 

the account numbers are suppressed in the report to prevent any possible misuse of the 

information. 

Would you kindly “purchase” your credit reports using the promo code and user ID’s that have 

been provided to you and inform our research associates that the report is ready to be printed. 

Indeed, we would like to get the reports to you so that you may review them this weekend for 

verification within the next week or so. If you find errors, we shall inform you whether they are 

likely to have had an adverse affect on any of your credit scores and, if so, how to proceed to get 

the errors corrected. Finally, we would arrange for you to draw new credit reports (without charge 

and after a suitable time) and determine if promised corrections have actually been applied to the 

credit-bureau files. 

Again, we appreciate your participation in this important study and trust that it will be a valuable 

exercise for you 

The e-mail address for our research associates is busresc2@umsl.edu. I believe that Aarti 

Dinesh made the arrangements for you and she will be helping you with the review. Her 

telephone number is (314) 516-5857. 

Sincerely, 
Exhibit 12 – Follow-up Survey to Assess the Process and Confirm 

Dispute Outcomes 
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?