Prior criminal activity can also be a predictor of future action. A 2018 report shows that rates of recidivism are significant.  This is a key point CDIA made when it filed a follow-up comment in January 2020 to the CFPB and the FTC in response to their Accuracy in Consumer Reporting Workshop in December 2019.  CDIA served on two of the four panels at that conference to, among other things, remind the Commission and the Bureau that consumer reports are highly reliable and proven to be accurate.  CDIA’s comment in advance of that workshop, from December 2019, is also online.  All comments filed in connection with that workshop are available online.