Subject: File No. S7-18-11
From: Myrna D Gardner

June 14, 2011

I strongly support the implementation of these rules. I asked that agencies be required to post on each of the three major consumer credit rating firms TransUnion, Experian, Equifax post on their main (first page) websites the methodology of how a consumer gets a 800 rating, 700 rating, 600 rating and so on. In business performance measurements are used every day. Rules regarding penalties and points associated with penalties are defined.

Publicly provide along with the publication of the credit rating disclosure about the credit rating and the methodology used to determine it.

I believe the only way this could be effective and beneficial to Americans is to have a MAJOR financial penalty for each day the credit agencies organizations businesses DO NOT post and implement. Otherwise, its just words. There must be a defined effective date and severe penalties for non-performance.