Managing customer address discrepancy between a customer address on business file, address provided by the customer, and customer address in the credit reporting agency reports is mandatory and a reasonable identity risk management practice. Often, an address discrepancy may be a red flag which indicates that the person presenting identifying information such as the home address may not be the actual person.
For effectively managing customer address discrepancies, consumer credit reporting agencies must notify parties requesting a credit report regarding address discrepancies between address provided by the requesting party and the address that the credit reporting agency has on file for the consumer when both addresses substantially differ from each other. And, parties which receive address discrepancy notices must have reasonable policies and procedures for validating customer address discrepancy notifications received from credit reporting agencies.
Entities which request consumer credit reports must develop and execute reasonable policies and procedures when the report user receives an address discrepancy notification from a credit reporting agency. Specifically, a report user must have policies in place to:
Examples of reasonable policies and procedures enabling a report user to form a reasonable belief concerning a consumer's identity include:
The policies and procedures for address reconciliation must ensure that the report user will furnish the consumer's address as part of the information it regularly furnishes to the credit reporting agencies for the reporting period in which it establishes a relationship with the consumer.