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Technical Options Harmonization Paper by sofiaie

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									Harmonization of Legislative Measures for
      Credit Reporting In Canada

        Stakeholder Consultation




              June 15, 2007




    Federal, Provincial and Territorial
     Consumer Measures Committee

               cmcweb.ca
BACKGROUND


The Consumer Measures Committee (CMC), which includes a representative from the
federal government as well as from every province and territory, was created under
Chapter Eight of the Agreement on Internal Trade. The CMC provides a federal-
provincial-territorial forum for national cooperation to improve the marketplace for
Canadian consumers, through harmonization of laws, regulations and practices and
through actions to raise public awareness. The CMC also provides support and
develops policy proposals for Federal-Provincial-Territorial Ministers Responsible for
Consumer Affairs.

The objective of this consultation is to share information and solicit feedback
from key stakeholders on proposals to harmonize consumer reporting legislation
across Canada.


A consumer report is a written, oral or other form of communication regarding the
credit or personal information of a consumer. The most widely known form is the
traditional credit report, but many other examples exist. A wide variety of organizations,
such as insurance underwriters, residential leasers or employers use the reports as part
of their decision making process when managing risks.

Any person who supplies reports about consumers, regardless of status as a
corporation or non-profit organization, is considered a reporting agency and must meet
the requirements of relevant federal and provincial legislation. This includes, but is not
limited to, the major national credit reporting agencies and reporting agencies
specialized in areas such as investment, insurance, and tenancy.

In Canada, the reporting industry is regulated under provincial and/or federal privacy
legislation, and, in some cases, under provincial consumer protection legislation.

The federal Personal Information Protection and Electronic Documents Act (PIPEDA)
regulates the collection, use and disclosure of personal information. Some provinces
have enacted their own broader privacy legislation that reflects substantially similar
principles. It must be noted, however, that provincial consumer reporting legislation
does not always align with PIPEDA and most of the provincial privacy laws, as the
consumer reporting laws pre-date the privacy laws.

Consumer reporting legislation is broadly similar across Canada. Provincial laws define
what qualifies as a reporting agency, and, depending on the province, establish the
nature of the information that cannot be included in a report, the length of time it can be
included, the purposes for which a report can be requested, basic mechanisms for
correcting errors, and methods of consumer consent and access.
However, there are some inconsistencies that could result in consumer information
being treated differently by reporting agencies, based on the province. This can also
create costs for reporting agencies in having to administer different rules, province by
province. For example, businesses and individuals that access information from
reporting agencies must adjust to different limitations on the nature of the information
available to them, and on the length of time information may remain on a report.

The Consumer Measures Committee (CMC) is reviewing consumer reporting
legislation to establish a template for harmonized legislation to protect consumers and
reduce the regulatory burden on reporting agencies. Measures to combat identity theft
related to credit reporting were the subject of a CMC consultation in 2005. These are
not addressed in this consultation document, but amendments to consumer reporting
legislation in regard to identity theft may arise as a result of that previous CMC
consultation.


PART I. DEFINITIONS

File: All of the information pertaining to an individual that is recorded and retained by a
reporting agency, regardless of the manner, form or location in which the information is
stored.

Personal information: Information about an identifiable individual, including but not
limited to information about an individual‟s name, age, character, health, medical
information, reputation, physical or personal characteristics, mode of living, credit
information, occupation, current and previous employers, place or places of residence,
marital status, dependents, educational or professional qualifications, financial details or
history, assets or any other matter concerning the individual.

Report: Includes any release of personal information from a file, whether in written, oral,
electronic or other form.

Reporting agency: Any person who, related to a business transaction or that carries
out the activities of providing reports, personally or through a representative, establishes
files on other persons and prepares and communicates to third parties reports bearing
on character, reputation or solvency of persons to whom the information contained in
the files pertains.
PART II. BASIC PROVISIONS, NOT SUBJECT TO CONSULTATION

There are basic provisions that are already included in the provincial legislation
governing reporting agencies in a majority of provinces, and for which no substantive
changes are proposed, or are considered by the CMC to be central elements in the
regulation of reporting agencies. As such, no options for consultation are provided on
these provisions:

   1. Information regarding judgments against the consumer cannot be reported
      unless it includes the name and address of the creditor and amount of the
      judgment.

   2. Information regarding court actions cannot be reported unless it includes the
      current status of the court action.

   3. Information regarding criminal convictions must be expunged from the file if an
      absolute discharge or pardon is granted.

   4. Information regarding criminal charges cannot be reported unless the current
      status of the charge is included. Charges on which an individual has been found
      not guilty and charges that have been withdrawn or are otherwise no longer
      before the courts cannot be reported.

   5. Information regarding race, creed, colour, ancestry, ethnic origin, political
      affiliation and sexual orientation cannot be reported.

   6. The source of information must be disclosed in all reports and maintained in the
      file until the information is purged.

   7. Reporting agencies are prohibited from requiring consumers to waive any rights
      or release the reporting agency from liability before receiving a report or file.

   8. Data accuracy requirements are addressed by privacy legislation (for example,
      PIPEDA, Schedule 1, 4.6 Principle 6 – Accuracy).

   9. Health care and medical information should be excluded from files and reports,
      except for debts relating to medical goods and services. Health care and medical
      debts may not identify the services or include details related to the health care or
      medical status of the individual.

   10. The end-user of a report (as opposed to the entity that provides the end-user with
       access to a report) must notify an individual when a report results in or plays a
       significant role in the denial of a benefit or service or an increase in the cost of a
       benefit or service. The end-user must also notify an individual when information
       from a third party (i.e., not a reporting agency) results in, or plays a significant role
       in, the denial of a benefit or service, or an increase in the cost of a benefit or service.
PART III. PROVISIONS FOR CONSULTATION

Your views are being sought on the issues outlined in this Part. Please place an X
beside the appropriate response and provide comments. There are 10 sections.

Section 1. Information to be Excluded From Reports After Six Years

Personal and credit information, particularly when adverse, is central to determining if
credit will be made available. It is also central for creditors when determining whether an
individual is a good credit „risk.‟ The period covered by a credit history plays an
important role in this determination. A national standard of reporting adverse information
for a maximum of six years is proposed.

It is proposed that the following types of information be excluded from reports after six
years:

1a) Debts, from the date of last payment or the date of first default, which ever is later.

     __       Agree
     __       Disagree

Comments:



1b) Judgments, from the date of the judgement, unless the creditor or the creditor‟s
    agent confirms in writing that the judgment remains unpaid in whole or in part and
    the confirmation appears in the file.

     __       Agree
     __       Disagree

Comments:



1c) Convictions for offences against a law of any jurisdiction, from the date of
    conviction, or, where the conviction resulted in imprisonment, from the date of
    release, or, if parole is granted, from the completion of parole.

     __       Agree
     __       Disagree
Comments:




1d) Lawfully imposed fines, taxes or premiums, from the date they were imposed,
    unless confirmed in writing every six years as unpaid by the government or
    government agency responsible for collection.

     __      Agree
     __      Disagree

Comments:




1e) Other adverse personal information, from the date of the event which lead to the
    adverse information appearing in the report.

     __      Agree
     __      Disagree

Comments:




1f) Currently, the most common time frame among provinces for reporting adverse
    information is six years. This is also the shortest period. Is a national standard of
    six years for reporting adverse information the most appropriate time frame?

     __      Yes
     __      No

Comments:
Section 2. Bankruptcy Information

Bankruptcies are reported in consumer reports and are key factors in determining if
credit will be made available. How bankruptcies are reported is of great importance to
both the business and the individual, particularly in cases where an individual has
declared bankruptcy more than once.

Most Canadian jurisdictions have reporting legislation that addresses this issue in broad
terms. For example, in Ontario, the Consumer Reporting Act currently restricts the
release of information on a bankruptcy to seven years after the date of discharge,
except where the individual has been bankrupt more than once, with no secondary
limitation.

It is proposed that if an individual is declaring bankruptcy for the first time, information
regarding that bankruptcy may not be reported after six years from the date of
discharge.

A question arises when a consumer declares bankruptcy more than once. Users of
reports would benefit from having more information about the credit history of an
individual with a current bankruptcy on file (that is, a bankruptcy that is still within the
six-year post-discharge period), including the existence of one or more bankruptcies in
the past which may have been removed from the file once their own six-year reporting
period ended. On the other hand, the individual would benefit if any previous
bankruptcy could not be reported past its own six-year exclusion period, under any
circumstance.

Please indicate which standard you feel should apply if an individual is declaring
bankruptcy and has done so before:

     __       Information regarding a bankruptcy cannot be reported more than six
              years after the date of discharge of that specific bankruptcy, regardless of
              subsequent bankruptcies.
     __       Information regarding all previous bankruptcies can be reported up until
              six years after the date of discharge of the most recent bankruptcy in the
              file.

Please indicate why.




Comments:
Section 3. Information Related to a Consumer Proposal, Orderly Payment of
           Debts (OPD) Program / Consolidation Order and “Substantially
           Similar” Arrangements

Part III of the Bankruptcy and Insolvency Act sets out the process for consumer
proposals, whereby a consumer can make a proposal for repayment of debt to
creditors when the amount owed is under an amount set in the statute; Part X of the Act
details the Orderly Payment of Debts procedure, which allows a person to pay debts
under the governance of provincial courts.


In 2002, the Personal Insolvency Task Force stated that:

      …current credit rating practices yield a result that is directly contrary to the
      policy choice of Parliament to encourage proposals by personal debtors. The
      adverse credit scores of individuals who have made proposals will almost
      invariably remain on their credit records longer, and sometimes substantially
      longer, than they remain on the records of those who choose bankruptcy.


In a review of the Bankruptcy and Insolvency Act in 2003, the Standing Senate
Committee on Banking, Trade and Commerce reached a similar conclusion:

      …the current credit rating system contains perverse elements and does not
      reward efforts by insolvent debtors to honour a greater portion of their
      obligations than would be the case if such debtors were to go into
      bankruptcy. In some sense, fairness is lacking [in the credit reporting
      system].1

In response to these concerns, the following retention periods are proposed:

3a) For consumers successfully completing a consumer proposal (as per Part III of
    the Bankruptcy and Insolvency Act): three years from successful completion of the
    proposal, with a maximum retention period capped at 6 years from the date of
    filing.

      __        Agree
      __        Disagree
      __        A shorter cap should be considered for those who successfully complete a
                consumer proposal. Please specify:


1
 Debtors and Creditors Sharing the Burden: A Review of the Bankruptcy and Insolvency Act and the Companies’
Creditors Arrangement Act (Report of the Standing Senate Committee on Banking, Trade and Commerce,
November 2003), pg. 78-79.
Comments:




3b) For consumers successfully completing an orderly payment of debt (OPD)
    program or consolidation order (as per Part X of the Bankruptcy and Insolvency
    Act): removed upon successful completion.

     __      Agree
     __      Disagree

Comments:




Part X of the Bankruptcy and Insolvency Act is not in force in all provinces in Canada; a
consumer does not have access to this legislative option in those provinces where it is
not in force. However, in at least one province that has not opted in to Part X, a non-
legislative debt repayment program is offered in the marketplace that is substantially
similar to Part X (i.e. the consumer is required to repay 100% of their debts over a
specified period of time).

3c) For consumers successfully completing a debt repayment program that is
    substantially similar to Part X: removed upon successful completion.

     __      Agree
     __      Disagree

Comments:
Section 4. Disputes and Redress

Ensuring that the information collected is limited to the purposes for which it was
collected and regulating the use and disclosure of that information is essential under
privacy law. There is also the need for the ability of individuals to access and correct
inaccurate information in a timely fashion.

Creditors and their agents vary in the frequency and diligence with which they provide or
confirm credit information to reporting agencies. The end result is that reports provided
by reporting agencies can have information that is incorrect, out-of-date, or in the wrong
file altogether. Individuals may also feel that an item in their report needs to be
explained or put into context.

Individuals need to be able to have incorrect or misleading information fixed or removed
from their file or to provide an explanation that will be included in their report.

PIPEDA requires that amended information in a report or a dispute statement involving
an unresolved challenge be transmitted to third parties who have access, where
appropriate. Consumer reporting legislation in many provinces requires that all parties
that have received a report in a period (often of one year) prior to the correction receive
copies with the corrected information. Schedule 1 of PIPEDA requires:
     4.9.5 When an individual successfully demonstrates the inaccuracy or incompleteness of
     personal information, the organization shall amend the information as required. Depending
     upon the nature of the information challenged, amendment involves the correction, deletion,
     or addition of information. Where appropriate, the amended information shall be transmitted
     to third parties having access to the information in question.

     4.9.6 When a challenge is not resolved to the satisfaction of the individual, the substance of
     the unresolved challenge shall be recorded by the organization. When appropriate, the
     existence of the unresolved challenge shall be transmitted to third parties having access to
     the information in question.


4a) What requirements should there be for reporting agencies and reports with regard
    to responding to consumer disputes about information on their report?

     __      Privacy legislation provides sufficient protection for individuals.
     __      Consumer reporting legislation should specifically require that reporting
             agencies inform previous recipients that corrections have been made.
     __      Consumer reporting legislation should require that the reporting agency
             notify the consumer that the correction has been made and that the
             consumer has the right to request that corrected reports be sent to
             recipients over the past year.
     __      Consumer reporting legislation should establish a standard with regard to
             correcting reports and providing previous recipients with corrected reports
             that goes beyond what is in the option immediately above (please indicate
             what standard should be established).

Comments:




4b) A consumer statement (of an unresolved dispute) must be kept on file with the
    item(s) it relates to and be provided with all reports that include the relevant
    item(s). PIPEDA requires that a file include the substance of the dispute but does
    not place an express limit on the details of the consumer statement that are
    provided in a report. Consumer reporting legislation in several provinces specifies
    a limit to the number of words for a consumer statement (of an unresolved
    dispute), which exists alongside a requirement that the consumer statement be
    included in all reports that include the disputed record. For example, the US Fair
    Credit Reporting Act, 15 U.S.C. § 1681, Section 611 (b), permits a limit on the
    number of words in a consumer statement:

     (b) Statement of dispute. If the reinvestigation does not resolve the dispute, the consumer may file
     a brief statement setting forth the nature of the dispute. The consumer reporting agency may limit
     such statements to not more than one hundred words if it provides the consumer with assistance in
     writing a clear summary of the dispute.

     A longer consumer statement (of an unresolved dispute) increases the costs
     relating to furnishing reports, and industry and business stakeholders have
     indicated that disputes are only occasionally considered by end-users. Should a
     consumer statement (of an unresolved dispute) be required to be included with all
     reports that include the relevant item, and should there be a limit on the number of
     words that a consumer statement can include?

     __      PIPEDA requirements for recording and reporting the substance of a
             dispute are appropriate.
     __      Disputes should be included in reports but have a limit of _____ words to
             reduce the length and costs of reports, if the reporting agency provides the
             consumer with assistance in writing a clear summary of the dispute.
     __      The existence of disputes should be noted on the report, and full
             descriptions be made available only upon request.

Comments:
Section 5. Consumer Consent and Consumer Notification

The release of information by a reporting agency can not only determine if an individual
gains access to a service or benefit, but can impact terms on which transactions are
entered, including their cost.

To ensure that individuals can exercise control over their personal information and that
they are aware that a report will play a role in the decision, individuals need to be aware
that a report will be requested. Currently, reporting agencies rely on the requesting
organization‟s assertion of consent.

Provincial reporting legislation may set specific requirements with regard to the nature of
consent. The Fair Trading Act in Alberta sets out the circumstances in which consent is
required and states that:

     44 (2.1) The express consent of an individual referred to in subsection (1) must be in a
     verifiable form, including but not limited to writing and audio recordings.

Privacy law addresses the issue of consent; for example, Schedule 1 of PIPEDA states:

     4.3.1 Consent is required for the collection of personal information and the subsequent use
     or disclosure of this information. Typically, an organization will seek consent for the use or
     disclosure of the information at the time of collection.

     4.3.2 The principle requires "knowledge and consent". Organizations shall make a
     reasonable effort to ensure that the individual is advised of the purposes for which the
     information will be used. To make the consent meaningful, the purposes must be stated in
     such a manner that the individual can reasonably understand how the information will be
     used or disclosed.

     4.3.3 An organization shall not, as a condition of the supply of a product or service, require
     an individual to consent to the collection, use, or disclosure of information beyond that
     required to fulfil the explicitly specified, and legitimate purposes.

5a) Please indicate which of the following options you support:

     __      Specific requirements should be set in consumer reporting legislation to
             ensure that the consent of an individual is obtained before a report can be
             released. Please indicate what specific requirements should be in place.
     __      Consumer consent is already required under privacy law and does not need
             to be addressed in consumer reporting legislation.


Comments:
5b) In order to determine if the information in their file is being used
    appropriately according to privacy and reporting legislation, and that
    consent has been obtained, if required, individuals need to be aware that a
    report has been issued, and to whom.

     Upon request from a consumer, reporting agencies are required to disclose to that
     consumer the identity of persons who have requested or who have received a
     report on that consumer, excluding requests from law enforcement agencies.
     Schedule 1 of PIPEDA states:

     4.9.3 In providing an account of third parties to which it has disclosed personal information
     about an individual, an organization should attempt to be as specific as possible. When it is
     not possible to provide a list of the organizations to which it has actually disclosed
     information about an individual, the organization shall provide a list of organizations to
     which it may have disclosed information about the individual.

     A reporting agency should provide this information covering what time frame?

     __      The previous year
     __      Other time period (please specify):


Comments:
Section 6. Clarity of Information in Report / Communication with Reporting
           Agencies

6a) Individuals may not fully understand the contents of their report. To this end,
    PIPEDA establishes requirements for providing background on the content of
    reports, including the requirement that information be in a form that is generally
    understandable. Schedule 1 states:

     4.9.4 The requested information shall be provided or made available in a form that is
     generally understandable. For example, if the organization uses abbreviations or codes to
     record information, an explanation shall be provided.

     Is the PIPEDA standard with respect to the clarity of information sufficient for a
     consumer report?

     __    Yes
     __    No. Please indicate why the PIPEDA standard applying to records that are
           produced in response to access requests is insufficient with respect to a
           consumer report, and indicate what standard would be more appropriate.

Comments:




6b) Consumer reporting legislation in the provinces varies with respect to how
    reporting agencies must communicate with consumers who are seeking
    information about the contents of their own credit file or related matters. Alberta,
    for example, requires that agencies have “properly trained staff available and
    accessible to explain to the individual any information furnished.” Establishing
    specific requirements may be onerous for smaller reporting agencies if they are too
    prescriptive.

     What standards should reporting agencies be expected to meet with respect to
     communicating with consumers?

     __      Reporting agencies should be required to communicate with consumers
             using the same method(s) they use to communicate with end-users.
     __      Specific standards should be established for consumer reporting agencies,
             such as having trained staff and a toll-free number. Please indicate the
             standards you feel should be required.

Comments:
Section 7. Consumer Access to Own File or Report

Consumer access to reports is central to allowing individuals to ensure that the
information in files relating to them is correct and that their information is not misused.
Allowing individuals to monitor and respond to the information in their file is an important
aspect for both consumer protection and in the credit granting process.

End-users are required to inform an individual when a consumer report has contributed
to a decision to deny or increase the cost of a benefit or service for an individual. Such
information can alert consumers to potential ID fraud, encourage them to work to
improve their credit rating, and allow them to identify errors in information in their file
and seek to correct them. Schedule 1 of PIPEDA states:

     4.9.4 An organization shall respond to an individual's request within a reasonable time and
     at minimal or no cost to the individual.

See also 4.9.5 (cited above, in the discussion under question 4) in regard to error
correction.

Provincial consumer reporting legislation, however, often requires that individuals have
access to their report for free in specific circumstances. The following three questions
address the number of times a consumer may obtain a free copy of their own report,
and the format in which it is to be provided.

7a) Should reporting agencies be required to provide one free report annually upon a
    request in writing, and whenever the individual is subject to an adverse decision
    stemming from their report and makes a request in writing?

     __        Agree
     __        Disagree

Comments:
7b) Recognizing the high number of credit transactions completed in one year, and the
    associated potential for an error to appear on a consumer report, some
    stakeholders argue that consumers should have more frequent access - or even
    unlimited access - to a free consumer report. However, more frequent free access
    would present a higher burden on reporting agencies.

     Considering this, is one free report annually the most appropriate limit/time frame?

     __     Yes
     __     No, free access to a consumer report should be unlimited.
     __     No, free access to a consumer report should be more frequent than one
            time per year, but should not be unlimited. Please identify what limit should
            be placed on free access.

Comments:




7c) Nova Scotia has taken the stance that a consumer should have free access to a
    consumer report regardless of the manner in which they ask to receive it (e.g. both
    mail and electronic access should be free). Other provinces require free
    disclosure only by mail. Reporting agencies claim that the costs associated with
    providing electronic access to consumer reports justify the charging of a fee for this
    type of access.

     With respect to consumer reports, should there be different rules depending on the
     method used by a consumer to access them?

     __     Yes. Please indicate what rules should exist for each method of access.
     __     No, there should be one set of rules (and all methods of access should be
            free).

Comments:
Section 8. Access to Files

Access to files containing personal and credit information is limited to protect
consumers. Many provinces limit the sale of files (as opposed to reports) to other
registered or licensed reporting agencies; other provinces limit access according to
privacy legislation. Federal privacy legislation may also restrict the sale of consumer
files without consumer consent.

Should the sale of files (as opposed to reports) by a reporting agency be limited?

     __     Yes, to recognized reporting agencies
     __     Yes, according to privacy law
     __     Barred, except in the case of the sale of the reporting agency


Comments:




Section 9. Access to Reports

The process of furnishing a report is an important one, as is the understanding of what a
report is being used for. Accordingly, consumer reporting legislation often places direct
limitations on the reasons for which a report can be furnished and requires that
consumers consent to the release or be notified of it.

In Alberta, the Fair Trading Act limits the release of a report to situations in which there
are reasonable grounds to believe that it is being provided: in relation to the extension
of credit, for the collection of a debt, for employment purposes, in connection with the
underwriting of insurance for that individual, to determine the eligibility of an individual
under a law, as a result of a direct business requirement (and with the consent of the
individual), or to a government agent. In most cases, the express consent of the
individual is required.

Should consumer reporting legislation establish specific rules for the furnishing of
reports, or should it be directed towards ensuring the informed, express consent of the
individual?

     __     Consumer reporting legislation should have specific limitations on the
            purposes for which a report can be furnished, and require informed,
            expressed consent (please specify the limitations).
     __     Consumer reporting legislation should require that the individual expressly
            and specifically consent to the furnishing of a report and be specifically
            informed as to the use and retention of the report by the requesting person.
            Legislation should not place any further limits concerning furnishing of
            reports.

Comments:




Section 10. Credit scores

Credit scores can play a key role in determining whether a consumer will have access to
a service or benefit. Reporting agencies have noted that credit scores are not kept in the
file and are not determined by the reporting agency, but rather by the lenders, often
based on proprietary formulas.

Consumers often do not understand the concept of credit scores or are interested in
seeing a sample score so as to have an indication of how creditors will respond to
requests for services or benefits. Industry has indicated there are technical and
commercial barriers to including credit scores with reports.

Should the Consumer Measures Committee undertake future work examining the issue
of credit scores?

     __     Yes. Please indicate why.
     __     No

Comments:




If you have additional comments on any of the issues included in this discussion paper,
or any other issues related to consumer reporting legislation, please use the space
below or attach another piece of paper to the end of the discussion paper. If your
comments are a continuation of your response to a question in the comments section,
please indicate the question number related to your comment.

Comments:




              Please be sure to complete the following two pages
Your information

1. Please indicate the following:

      Full Name:

      Organization (if applicable):

      Full Mailing Address:


      Telephone Number: (       )

      Email address:

      Preferred Language of Correspondence:


2. Please indicate to which group you belong:

      __     Private Business or Industry Association/Group
                    Please indicate the sector:____________________
      __     Consumer Association
      __     Academic
      __     Provincial Government
      __     Private Citizen
      __     Other (specify):

3. Please note that the Consumer Measures Committee (CMC) may publish
consultation responses.

A.    Please choose one of the following:

      __     I give CMC permission to publish this submission in its entirety.

      __     I give CMC permission to publish this submission with the exception of the
             responses to the following questions:

             __   Section 1             __ Section 5                __ Section 8
             __   Section 2             __ Section 6                __ Section 9
             __   Section 3             __ Section 7                __ Section 10
             __   Section 4

      __     I refuse to give CMC permission to publish this submission.
B.    Please choose one of the following if you have chosen one of the first two options
      from Section A:

      __    CMC may publish my name, and the name of the organization I represent.

      __    CMC may publish the name of the organization I represent, but not my
            name.

      __    I am responding as an individual private citizen. I give CMC permission to
            publish my name.

      __    I am responding as an individual private citizen. I do not give CMC
            permission to publish my name.




Thank you for your participation in this consultation.

								
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