ARTICLE 9. If personal data are transferred from one direct market to another for a direct marketing purpose, measures should be taken by the transferor to arrange strict security measures to assure that unauthorized access to the data is not likely during the transfer procedures. It is the responsibility of the direct marketer to whom the list is transferred to arrange strict security measures to ensure no unauthorized access to the list during its return to the original owner. ARTICLE 10. The Committee on Ethical Business Practice of DMA is charged with reviewing any complaints by individuals of violation of these Guidelines and shall take appropriate action. Members of DMA proudly display this MEMBER DIRECT MARKETING ASSOCIATION "Look for this symbol when you buy direct." DMA Ethics and In its continuing efforts to improve the practices of direct marketing and our relationship with customers, DMA sponsors several activities in its Ethics and Consumer Affairs Department. Activities are coordinated by a professional Director of Ethical Practices. Ethical Guidelines are maintained, updated periodically, and distributed to the direct marketing industry. A Committee on Ethical Business Practice investigates and examines mailings and offerings made throughout the direct marketing field. An Ethics Policy Committee initiates programs and projects directed toward improved ethical awareness in the direct marketing area. The "Dialogue" meetings between direct marketing professionals and consumer affairs and regulatory representatives facilitate increased communication between the industry and its customers. MOAL (Mail Order Action Line) assists consumers in resolving mail order complaints. MPS (Mail Preference Service) offers consumers assistance in decreasing the volume of advertising mail they receive. TPS (Telephone Preference Service) offers a decrease in home telephone sales calls. For additional information contact: Direct Marketing Association, Inc. New York, NY 10017-4646 1101 17th Street, NW Washington, DC 20036-4704 (202) 347-1222 dma Headquarters: Direct Marketing Association, Inc. 11 West 42nd Street New York, NY 10036-8096 (212) 768-7277 Fax (212) 768-4546 6 East 43rd Street New York, NY 10017-4646 (212) 768-7277 Fax (212) 599-1268 1101 17th Street, NW, Suite 705 Washington, DC 20036-4704 (202) 347-1222 Fax (202) 785-2231 THE WRITTEN STATEMENT OF THE NATIONAL COUNCIL OF SAVINGS INSTITUTIONS ON H.R. 3740, H.R. 4122, and H.R. 4213 PROPOSALS TO AMEND THE FAIR CREDIT REPORTING ACT The National Council of Savings Institutions appreciates this opportunity to submit written comments for the hearing record on H.R. 3740, H.R. 4122, and H.R. 4213, proposals to amend the Fair Credit Reporting Act. The National Council is a trade association representing savings banks and savings associations nationwide. Our members are both BIF- and SAIF-insured, mutual and stock, state and federally chartered and range in asset size from $22 billion to $9 million. In September 1989, the National Council submitted written comments in connection with the oversight hearings on the Fair Credit Reporting Act held by the Subcommittee on Consumer Affairs and Coinage. At that time, we stated that we found that, with very minor exceptions, the current statute was functioning in a very satisfactory manner in meeting the needs of financial institutions for the accurate information required to make credit-granting decisions on a day-to-day basis. Therefore, we believe legislation to amend the Fair Credit Reporting Act is unnecessary. We strongly urge, that if changes to the Fair Credit Reporting Act are considered by the Congress, the balance between the needs of the credit granting industry for accurate and timely information, and the rights of the consumer to privacy and knowledge of the contents of their individual reports, be preserved. We are aware of recent press reports regarding totally unauthorized persons obtaining individual credit reports. We understand, and share, the concern of both Congress and the public with this extremely serious matter. We would suggest, however, that an appropriate remedy would be to increase the penalties which appear in the current statute, i.e. a fine of not more than $5,000 or a prison sentence of not more that one year, or both. Should Congress enact amendments to the Fair Credit Reporting Act at some point in the future, we would strongly recommend that a provision increasing these penalties be included. There also seems to be a general concern, again both in Congress and with the public, regarding a lack of consumer information and understanding about the manner in which the credit reporting system actually functions. For example, the general public does not seem to have an understanding of the process used by credit grantors and credit reporting agencies in "prescreening." We share the concern with this lack of |