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Dreher Tomkies LLP
Attorneys at Law
2750 Huntington Center
41 South High Street
Columbus, Ohio 43215
Telephone (614) 628-8000
Fax (614) 628-1600



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AGENCIES SEEK COMMENTS ON PROPOSED PROCEDURES TO ENHANCE ACCURACY AND INTEGRITY OF CONSUMER REPORT INFORMATION

The Office of the Comptroller of the Currency, Federal Reserve Board, Federal Deposit Insurance Corporation, Office of Thrift Supervision, National Credit Union Administration and Federal Trade Commission have issued an interagency advance notice of proposed rulemaking and request for public comment to gather information useful for developing guidelines and regulations implementing Section 312 of the Fair and Accurate Credit Transactions Act of 2003 (FACTA). This section of the FACTA directs the agencies to (i) establish guidelines for use by persons that furnish information to consumer reporting agencies regarding the accuracy and integrity of information furnished, (ii) prescribe regulations requiring furnishers to establish reasonable policies and procedures for implementing the guidelines and (iii) prescribe regulations identifying circumstances under which a furnisher will be required to reinvestigate a dispute concerning the accuracy of consumer report information based on a direct request of a Consumer.

The agencies solicit public comment on issues relating to:(i) the criteria the agencies must consider when developing the accuracy and integrity guidelines, (ii) what constitutes reasonable policies and procedures for implementing the guidelines and (iii) the considerations the agencies must weigh when promulgating the furnisher reinvestigation rules. In particular, the agencies invite comment on a list of specific issues. Comments must be submitted on or before May 22, 2006.

Mike Tomkies