The Federal Trade Commission ("FTC") proposed rule that would require nationwide consumer reporting agencies ("CRAs") to provide a free electronic credit monitoring service to active-duty military consumers was published in the Federal Register. The proposal - which implements Section 302 of the Economic Growth, Regulatory Relief and Consumer Protection Act - would amend the Fair Credit Reporting Act. Comments on the proposal must be submitted by January 7, 2019.

As previously covered, the proposed rule would require CRAs to notify active-duty military consumers within 24 hours of any material additions or modifications to their credit file. The notification would be triggered by credit file changes, including: (i) new accounts opened in the consumer's name, (ii) inquiries or requests for a consumer report, (iii) changes to a consumer's name, address or phone number, (iv) changes to credit account limits and (v) "negative information," such as delinquencies, late payments, insolvency and any form of default.

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