Topics and Issues

LGBTQ+ (4) SSN matching (4) Transgender (5)

In February 2022, over 100 advocacy organizations sent a letter to the nationwide credit bureaus and CDIA on transgender name changes. The letter responds to the CDIA’s February 2 announcement, “Helping Transgender and Nonbinary Individuals Prevent Potential Disruptions to Their Credit,” that describes new policies at the Big Three credit bureaus to allow transgender and nonbinary consumers to submit name-change documentation to update the name on the credit reports.

The letter noted that there is “still more work to do and we are hopeful that we can continue working together to address the many pressing credit reporting needs that still remain for transgender and nonbinary consumers.” The letter makes specific suggestions:

To meaningfully address these problems [for transgender and nonbinary consumers] the credit reporting industry should take the following steps:

• • Utilize consumers’ full 9-digit Social Security numbers in matching algorithms to ensure credit information is associated with the correct credit file.
  • Facilitate name changes by having clear procedures to update a consumer’s name on their credit report when presented with a legal name change order, and ensure that staff are sufficiently trained in those procedures and are able to provide culturally competent service to transgender and nonbinary consumers.
  • Reduce the burden on transgender and nonbinary consumers to submit name-change documentation to each credit reporting agency by instituting a “one-stop” system that allows a consumer to submit a single request to have the legal name on their report updated, and ensures the request is communicated to all consumer reporting agencies.
  • Prevent the occurrence and recurrence of fragmented credit files by creating procedures to detect when a consumer changes their legal name with a creditor, to associate the new name with their credit file, and to consolidate a consumer’s credit information in their current and previous names in a single credit file — as the industry presently does when cisgender women and other consumers change their last names.
  • Prevent the disclosure of transgender and nonbinary consumers’ deadnames to landlords, employers, and underwriters by disclosing only a consumer’s current legal name in reports provided to credit report users.

The letter was led by:

• California Employment Lawyers Association (CELA)
• Center for LGBTQ Economic Advancement & Research (CLEAR)
• Equity California
• National Consumer Law Center
• Transgender Legal Defense & Education Fund (TLDEF)
• UC Berkeley Center for Consumer Law & Economic Justice