Address Discrepancy Rule
The nationwide credit reporting agencies — Experian, TransUnion and Equifax — are required to notify you when an address in their credit file for a consumer “substantially differs” from the address that you provide for the consumer when you request the credit report. New rules from the federal bank agencies and the FTC require you to confirm the identity of the consumer when you receive an address discrepancy notice from a credit reporting agency. These rules also may require you to reconcile the address provided by the consumer with the address in the credit reporting agency’s file, but only if you regularly furnish information to that credit reporting agency. Fair Credit ReportingAct (FCRA) — 15 U.S.C. § 1681c(h); Federal Reserve Board — 12 C.F.R. § 222.82; Federal Deposit Insurance Corporation — 12 C.F.R. § 334.82; FTC — 16 C.F.R. § 681.1; NCUA — 12 C.F.R. § 717.82; Office of the Comptroller of the Currency — 12 C.F.R. § 41.82; Office of Thrift Supervision
12 C.F.R. § 571.82.
If a credit report is pulled on a loan applicant who is a noncustomer, and there is an address discrepancy on the credit report, are we obligated to resolve the discrepancy if the loan is denied? You are only required to reconcile the address with the credit reporting agency if you “establish a continuing relationship with” the consumer.
If a creditor does not regularly furnish data to the credit reporting agency, is the creditor still required to furnish the correct address? In the ordinary course of business, if a creditor does not regularly furnish data to a credit reporting agency, there is no obligation to report correct addresses.
How do I communicate the corrected address to the credit reporting agency? You must furnish the verified address to the credit reporting agency with the other account data that you furnish to the credit reporting agency for the reporting period in which you establish the relationship with the consumer.
How do I “form a reasonable belief” that a credit report relates to the consumer for whom it was requested? Following procedures that you have implemented as a part of your Customer Identification Program (CIP) under the USA PATRIOTAct would satisfy this requirement. You also may compare the credit report with information in your own records or information from a third-party source, or you may verify information in the credit report with the consumer directly.