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ChatGPT's credit-score feature, rolling out since September 21 to U.S. Plus and Pro subscribers, comes with terms under which enrolling counts as 'written instructions' under the Fair Credit Reporting Act, letting OpenAI and Experian obtain and access information from the user's credit profile for purposes that include creating 'new features, products and functionality'. OpenAI's promise to delete the underlying report data within 30 days of disconnecting is in a help article, not in the terms.

7 min read

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On September 21 OpenAI began rolling out a credit-score feature in ChatGPT's Finances section to Plus and Pro subscribers in the U.S. It shows an Experian credit report and a VantageScore 3.0 score, updated monthly, through a soft inquiry that OpenAI says does not affect the score. Credit Score Terms published the same day say that enrolling provides 'written instructions' under the federal Fair Credit Reporting Act for OpenAI and its service provider, CSIdentity Corporation, which the terms call Experian, to obtain information from the user's credit profile. The listed purposes run from verifying identity and providing the score to improving the service and creating 'new features, products and functionality'. Finances conversations follow the user's ChatGPT model-training setting, and the terms point to how to opt out of training. OpenAI's help article says disconnecting Experian stops the sharing and deletes the underlying report data from OpenAI's systems within 30 days, but does not remove what is in past conversations or saved financial memories. The terms themselves say nothing about disconnecting, revoking or deleting.

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On September 21, OpenAI started rolling out a new ChatGPT feature: your credit score. Plus and Pro subscribers in the U.S. can connect their Experian credit report and get a VantageScore 3.0 score, an explanation of what is moving it, and alerts to important changes in the report.

What you agree to when you connect is written on a separate page, OpenAI's Credit Score Terms, published the same day. The permission covers showing you your score. It also covers improving OpenAI's service and building new products. The promise to delete your report data within 30 days of disconnecting is not in those terms. It is in a help article.

The permission, in full

Section 2 of the terms is one sentence:

You understand that by enrolling in the Credit Score Services, you are providing “written instructions” in accordance with the federal Fair Credit Reporting Act, as amended (“FCRA”), for OpenAI and our service provider, CSIdentity Corporation (“CSID” or “Experian”), to obtain and access information from your personal credit profile, to verify your identity, and to provide credit monitoring, reporting, and scoring products to you, to personalize your user experience, to improve our recommendations and insights to meet your unique needs, to provide you with personalized insights and guidance to enhance your financial well-being, to authenticate your identity and prevent fraud, and to improve our service and create new features, products and functionality.

The phrase "written instructions" comes from the statute. The Fair Credit Reporting Act says a consumer reporting agency "may furnish a consumer report under the following circumstances and no other", then lists them. Court orders and certain subpoenas come first. The second is:

In accordance with the written instructions of the consumer to whom it relates.

Under the terms, enrolling is that instruction. OpenAI's help article on the feature describes what follows: with your authorization, Experian "provides your ongoing credit report, score, and monitoring alerts to ChatGPT." The score and report update monthly.

Two sections, two descriptions of purpose

Section 5, on data handling, names one purpose. It says "OpenAI receives your Credit Information for purposes of providing the Credit Score Services to you." The terms define Credit Information as "Your credit score and report". Section 2 covers "information from your personal credit profile", and its list ends with creating "new features, products and functionality". The terms do not say which information is used for which purpose.

OpenAI's general Service Terms, marked updated September 21, gained a sentence that was not in a September 11 archived copy of the page: "Your use of credit score services, such as connecting to and accessing credit scores, reports, monitoring, and personalized insights, is also subject to the Credit Score Terms". Where the credit terms conflict with OpenAI's other agreements, they say "these Terms will control with respect to your use of the Credit Score Services".

Training is a separate switch

Section 3 is also one sentence: "If you do not want us to use your content to train our models, you can opt out by following the instructions in this article". The linked page says that for ChatGPT "we may use your content to train our models" and that "Once you opt out, new conversations will not be used to train our models." It does not say what happens to conversations from before the switch. Conversations in Temporary Chat are not used for training.

The help article says "Your conversations with Finances follow the same model training settings you choose across ChatGPT." The setting is under Settings, then Data controls.

None of these pages says whether the Experian report itself, as distinct from what you say about it, counts as "your content" in section 3. OpenAI's privacy policy, updated September 10, defines Content to include "data from connected services" and says OpenAI "may use Content you provide us to improve our Services, for example to train the models that power ChatGPT". It does not mention credit reports.

The identity check can use your phone carrier

Section 4 lets OpenAI and its providers, including Experian, verify you "using the phone number, date of birth, and other details you provide, including information from your wireless carrier where available, solely to confirm your identity and prevent fraud."

Those details go into Experian's form, not the chat. The help article says: "Make sure to enter personal information and verification codes in Experian's form, not in your conversation with ChatGPT."

The pull itself, section 1 says, is a soft inquiry, "which does not affect your credit score." The same section says "Scores are educational and may differ from those used by lenders." VantageScore 3.0, the disclosure adds, "is used by some but not all lenders."

Who can use it

The release notes say the feature is rolling out "to Plus and Pro users in the U.S. on web, iOS, and Android. Some eligible users may not see it right away." The terms require U.S. residents or residents of U.S. territories, and add: "We reserve the right to refuse access to Credit Score Services at any time without notice to you." You do not need to connect a bank account first; the help article says the Experian connection is separate from bank connections made through Plaid.

How to leave

The terms do not mention disconnecting, revoking the authorization or deleting anything. The help article does:

You can disconnect from your Experian credit score and reports at any time, including without removing your bank connections. This means Experian will stop sharing credit scores and reports with ChatGPT, and OpenAI will also delete the underlying Experian credit report data from OpenAI systems within 30 days. Disconnecting does not remove information from past conversations or financial memories, which you can delete separately.

By the article's account, removing your credit information takes separate steps:

  • Disconnect Experian. Experian stops sharing, and OpenAI deletes the underlying report data from its systems within 30 days. Disconnecting does not touch your credit file or any Experian service you use on your own.
  • Delete conversations in which your credit came up.
  • Delete financial memories, the details you share that ChatGPT saves for later finance conversations. They are viewed and deleted from the Finances page, via the three-dot menu.

If you only want the alerts to stop, the article says they can be turned off in notification settings without disconnecting.

For a wrong entry on your report, go to Experian. "ChatGPT cannot file a dispute, change your credit report, or freeze your credit for you."

What the record does not say

  • How long the authorization lasts. Neither the terms nor the help article says whether it ends if you cancel Plus or Pro without disconnecting.
  • What 'new features, products and functionality' covers, or how long OpenAI keeps the report while you stay connected.
  • Whether the report is used for training. The training setting is described for conversations and content; no page says how it applies to the report.
  • Where the Experian-only switch is. The article places the control for disconnecting Finances as a whole in Settings, and says Experian can be disconnected separately, without naming where.
  • What Experian's form says. The help article says you "authorize access to your credit data" in Experian's own form. Hugin has no ChatGPT account and could not see it, or the screen where a user agrees.
  • How many people have connected, or how the data has actually been used. None of the pages gives a figure, and this record is a reading of terms, not of practice.

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