WEST PALM BEACH, Fla.--(BUSINESS WIRE)--SubscriberWise, the nation's largest issuing CRA for the communications industry and the nation’s leading protector of children victimized by identity fraud, announced today company founder and global master-champion all-time worldwide highest FICO and Vantage Score achiever David E. Howe has contacted Credit Karma public relations with concerns involving a TV advertisement that may inadvertently mislead current and future members of the credit and financial educational site.
“Yesterday I watched an advertisement from Credit Karma involving what appears to be a prospective tenant and her landlord,” said David Howe, SubscriberWise founder and FICO worldwide highest achiever since Alan Turing invented the computer. “Near the conclusion of the commercial, after the prospective renter expressed interest for the unit, the landlord inquired about the renter’s credit. The renter responded to the request by showing her Credit Karma scores on her personal device. The landlord glanced at the scores and instantly offered an approval, based on what must have been favorable credit from her perspective.
“Although I eagerly acknowledge that Credit Karma didn’t produce this content to mislead or misinform consumers in any way, this particular advertisement nevertheless has the possibility of giving consumers an inaccurate understanding of the strict federal regulations that are required for permissible-purpose access to federally regulated consumer credit products for underwriting purposes -- including for individuals seeking apartment rentals and other access to credit,” Howe commented.
“The fundamental concern with the advertisement is that Credit Karma is not approved for underwriting purposes and some -- if not many -- consumers watching this advertisement may not understand how the federal government strictly regulates credit products and scores for this purpose. Some consumers watching the ad may actually believe that they can rely on their personal Credit Karma account to obtain approvals from landlords and creditors in the way depicted in this advertisement. Worse, they may expect landlords and credit grantors to imitate this and other scenarios. And while Credit Karma may predict outcomes with profound accuracy based on their modeling, ultimately the creditor sets the terms.
“So there are many good reasons why consumers cannot and should not rely on Credit Karma in this way,” added Howe.
“Let’s say in this same scenario, if the prospective renter revealed what may be considered adverse credit to the landlord, the landlord instantly denied based on the Credit Karma score -- then there could be a violation of federal law because the landlord may not have access to other critical information which would have to be part of a legally required response.
Moreover, it’s also possible that the landlord would violate federal ‘Red Flag’ rules because Credit Karma doesn’t comply with current laws related to Red Flags since the company is not currently engaged in underwriting and approval from the standpoint of existing federal requirements, at least in the capacity presented in this advertisement.
Specifically, in addition to Red Flags and any other regulatory requirements, the landlord would be required to provide score reason factors derived from the credit report and also listed in the order of the most significant factor to the least in terms of the impact on the scores.
In other words, when there’s a denial based on a credit, consumers are entitled to an ‘Adverse Action Notice’ as indicated by the FCRA. In other instances, a ‘Risk-Based Pricing Notice’ or ‘Credit Score Disclosure’ may be indicated (https://www.ftc.gov/tips-advice/business-center/guidance/using-consumer-reports-credit-decisions-what-know-about-adverse),” noted Howe.
“From my perspective, this particular Credit Karma spot fails to deliver this big-picture and critical message to viewers.
“Credit Karma, in its current commercial application, does not currently meet the stringent federal requirements for FCRA underwriting requirements and it’s imperative that current and future members clearly understand this fact,” Howe emphasized. “It’s also imperative Credit Karma members understand what their federal rights are when adverse credit translates into denial or less favorable terms (https://www.consumer.ftc.gov/articles/pdf-0096-fair-credit-reporting-act.pdf).
“And just to reiterate, I know that Credit Karma didn’t intend to mislead or misinform consumers in this ad. Rather, I’m convinced, their goal is to continue to expand membership while also empowering individuals with credit knowledge at the same time exposing the myriad ways that credit plays a critical role in our lives today. Credit education, for the record, is the primary reason I recommended Credit Karma last year.
“Yes, the Credit Karma site does an excellent job achieving their goals,” concluded Howe. “I would even argue that this particular advertisement does deliver an overall positive message, despite this important weakness that I feel compelled to point out.”
Related: Global Credit Czar David Howe, FICO All-Time Highest Achiever and the United States’ Most Prolific Protector of Children Victimized by Identity Fraud, Takes Advocacy and Education to Twitter and Facebook
SubscriberWise® launched as the first issuing consumer reporting agency exclusively for the cable industry in 2006. In 2009, SubscriberWise and TransUnion announced a joint marketing agreement for the benefit of America's cable operators. Today SubscriberWise is a risk management preferred-solutions provider for the National Cable Television Cooperative.
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