The Holder Rule is one of the most important actions the Federal Trade Commission has ever taken in preventing and remedying unfair and deceptive practices in the marketplace. When a seller of a good or service originates or helps arrange credit, the Rule allows consumers to raise the seller’s misconduct as a basis for bringing claims or defenses against the entity holding the debt. Because of the Rule’s enormous impact in preventing and remedying unfair and deceptive seller practices, CFA urges the Commission to retain the Holder Rule’s strong provisions and to take eight steps that will further facilitate the Rule operating as it should.