January 26, 2016 | By Greg Fisher

From: Greg Fisher [mailto:greg@truthandfalsity.com]
Sent: Tuesday, January 12, 2016 7:19 AM
To: Richard Ketchum, CEO, FINRA (via Nancy Condon)
Subject: credit score, finra, culture, 30

See this message and your response at http://creditscoring.com/interaction/2016/01/12-finra-utilization-thumb.html. I am with the media, am writing about your organization and I am on a deadline. The deadline is tomorrow.

What is the name of the person who wrote the number in the sentence, "A good rule of thumb is not to exceed 30% of the credit limit on a credit card"?

Who wrote those words?

--
Greg Fisher
Truth and Falsity
truthandfalsity.com
The Credit Scoring Site
creditscoring.com
PO Box 342
Dayton, Ohio 45409-0342
mobile/text 937-681-3224

From: Greg Fisher [mailto:greg@truthandfalsity.com]
Sent: Friday, January 22, 2016 8:34 AM
To: Michelle Ong, Media Relations, FINRA
Cc: Richard Ketchum, CEO, FINRA (via Nancy Condon)
Subject: RE: credit score, finra, culture, 30 II

I sent a message 10 days ago. Did anyone get it?

Please reply.

--
Greg Fisher
Truth and Falsity
truthandfalsity.com
The Credit Scoring Site
creditscoring.com
PO Box 342
Dayton, Ohio 45409-0342
mobile/text 937-681-3224

From: Greg Fisher [mailto:greg@truthandfalsity.com]
Sent: Friday, January 22, 2016 9:41 AM
To: [Pellecchia]
Cc: Michelle Ong, Media Relations, FINRA
Subject: RE: credit score, finra, culture, 30 II

See a message with your name in it below.

--
Greg Fisher
Truth and Falsity
truthandfalsity.com
The Credit Scoring Site
creditscoring.com
PO Box 342
Dayton, Ohio 45409-0342
mobile/text 937-681-3224

Pellecchia verbally confirms receipt of the message.

From: Greg Fisher [mailto:greg@truthandfalsity.com]
Sent: Friday, January 22, 2016 3:39 PM
To: ombuds@finra.org
Subject: RE: credit score, finra, culture, 30 II

Answer the question, please: What is the name of the person who wrote the number in the sentence, "A good rule of thumb is not to exceed 30% of the credit limit on a credit card"?

--
Greg Fisher
Truth and Falsity
truthandfalsity.com
The Credit Scoring Site
creditscoring.com
PO Box 342
Dayton, Ohio 45409-0342
mobile/text 937-681-3224

From: Ombudsman's Office [mailto:Ombuds@finra.org]
Sent: Friday, January 22, 2016 4:04 PM
To: Greg Fisher
Subject: Auto Reply - FINRA's Office of the Ombudsman

Confidentiality Notice:: This email, including attachments, may include non-public, proprietary, confidential or legally privileged information. If you are not an intended recipient or an authorized agent of an intended recipient, you are hereby notified that any dissemination, distribution or copying of the information contained in or transmitted with this e-mail is unauthorized and strictly prohibited. If you have received this email in error, please notify the sender by replying to this message and permanently delete this e-mail, its attachments, and any copies of it immediately. You should not retain, copy or use this e-mail or any attachment for any purpose, nor disclose all or any part of the contents to any other person. Thank you.

From: Greg Fisher [mailto:greg@truthandfalsity.com]
Sent: Tuesday, January 26, 2016 1:36 PM
To: Cindy Foster, ombudsman, FINRA
Cc: Susan Keating, president & CEO, NFCC
RE: credit score, finra, culture, 30 II, #creditscares, #1601S

[ATTENTION: FINRA ombudsman Cindy Foster. Ms. Foster, provide a copy of this message to Richard Ketchum, FINRA CEO, please.]

Richard G. Ketchum, chairman and CEO
FINRA
1735 K Street
Washington, DC 20006-1506
via internet social media and email

See this message now at http://creditscoring.com/influence/government/finra/ketchum-advice.html. Your response will be published with it. I am with the media, am on a deadline, and I am writing about you, Mr. Ketchum. The deadline is tomorrow.

Stop publishing information about credit scores, please. Create a void so that the people who actually know the secret formulae are forced to reveal more about them. Do not add to the collective national confusion.

Fair Isaac gets one of only two links in a document you published where an anonymous writer states, "A good rule of thumb is not to exceed 30% of the credit limit on a credit card."

Who wrote those words? What is the name of the person who wrote the number in that declarative sentence?

On the contrary, Ethan Dornhelm, an actual credit score expert from Fair Isaac, the FICO score company said, "There is some misconception out there that there's a hard and fast threshold above which the consumer will start hurting their score, below which it's helping the consumer's FICO score."

The article that quotes him continues, "Dornhelm says a consumer's score takes the greatest blow as the person approaches 100 percent utilization, but could not offer an ideal threshold for consumers to heed."

Barry Paperno, formerly with Fair Isaac, wrote about the issue, too. The title of his piece

Forget the 30 percent credit utilization 'rule' - it's a myth

Subtitle

Your score won't fall off a cliff at 31 percent or soar at 29

Forgetting everything we think we know about credit scores for a moment, it seems strange that I can't use even half of a credit line for fear of what you say "Hurts a Credit Score." Indeed, Fair Isaac's general rule is 50 percent, not 30. Even Santa Claus used 100 percent of one of his credit cards–and his 757 score may qualify him for favorable lending terms!

Anonymity makes one brave. Is 30% just misplaced Yankee prudence? Why not 25, or 35? What's so good about 30? That bizarre idea (and the other 70 percent of credit lines sitting idle) could actually be stifling the American economy by creating a nation of neurotics. Who do you think you are?

Since your document contains no author's name, the only thing left for me to do is to attribute it to you and your entire organization. See that everybody in it gets a copy of this, please. Accountability is lacking, but as for transparency, I can see right through you.

Again, the overriding solution to your problems is to stop writing about credit scoring, altogether. Obviously, now, there are enough pages of publicly available information on the topic to eliminate the need for you to foist one more nanny-state summary on citizens and screw it up in the process. I realize that securities dealers know everything about everything and are more than willing to provide their glib, expert analyses whenever asked (and then some). Give them something written by their regulator and we're really cooking. Do the people in the industry you oversee have exposure to credit scores in the regular course of business, in their day-to-day operations?

Create a vacuum of credit score information–one that can only be filled by the scorekeepers, the keepers of the secrets. Force their hand.

Furthermore, the FINRA Investor Education Foundation states, "Credit scores are also used more and more by potential employers, landlords, utility companies and others."

What's the big idea? Employers do not use credit scores. I looked into it.

And, if they're not even using them, they're certainly not using them "more and more." We're in my office, now: Credit Score Myth 2 is an urban legend so old, crude and well-known to be balderdash that I made it a litmus test to gauge sheer veracity of a person (your 30 percent solution is Myth 4, by the way–and it is going gangbusters!). Today, Myth 2 is a joke—so eastern seaboard. So symposium, so conference, so luncheon—so laughable. So New Yorky.

So pathetic.

Please tell me that that is not on one of your exams! Acknowledge your error and correct that information today, or—better yet—use your long arm: Open an investigation and produce the names of two employers who use credit scores in employment screening. They'll be kicked out of the system, and you'll be famous.

And I'll be a monkey's uncle.

I would like nothing more than to move on to broader topics in money, but if I can't get even the most miniscule amount of cooperation from people in high places, then I'm sticking with the same lines I've used since the last millennia to make a point about megalomania in an environment of false information. Accuracy takes time. Slop does not, and I am not going to let you get away with it.

I would have gotten to it sooner or later, but the reason this is happening now is your mention of "culture." Culture, schmulture. That's just too gray, and besides, your organization's culture stinks, too. This sorry episode proves it, but look how easy that was to say. A person doesn't need intrigue like this to say it. Don't you want something more tangible? Truth, as a theme, is black and white and far better. If you're going to use some highfalutin idea to go out on, use truth (as in fact). Once you learn a few fundamentals about it (and its opposite, falsity), you have a foundation for anything–a walk in the park. Truth is simple. It's easy. Try it. Here's your chance.

Reply directly to this message by tomorrow, to, at least, acknowledge it.

You are wrong, but don't worry; there is enough blame to go around. Welcome to the fray.

--
Greg Fisher
Truth and Falsity
truthandfalsity.com
The Credit Scoring Site
creditscoring.com
PO Box 342
Dayton, Ohio 45409-0342
mobile/text 937-681-3224

PS. Isn't this fun? Another litmus test: Your address is wrong. The comma goes before "DC," not after it. Make a correction. Then, again, you're probably not used to being told what to do, so I'm not holding my breath.