The Commission is particularly concerned with the data suggesting that the separate
landing page, as proposed, would cause consumer confusion. Indeed, based on the comments
submitted, the Commission is persuaded that the separate landing page, which would not be in
close proximity to the relevant claims, has the potential to confuse consumers and create
suspicion about the legitimacy of the disclosure in this context.118 Because the very purpose of
section 205 of the Act and the amendments to section 610.2 of the original Rule is to reduce such
confusion, the Commission has determined to eliminate the separate landing page in favor of a
prominent disclosure on the website page(s) where the free credit report claim appears, as well
as on each page of the ordering process.119
