Customer Address Discrepancy

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.

Credit Report User Responsibility

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: 

  1. Enable the report user to form a reasonable belief that a consumer report relates to the correct consumer; and 
  2. Reconcile the address of the consumer with the credit reporting agency by providing to the agency an address that the report user reasonably has confirmed to be accurate when the report user:
  • (a) establishes a new continuing relationship with the consumer,
  • (b) can form a reasonable belief that the consumer report relates to the consumer about whom the report user has requested the report; and
  • (c) regularly and in the ordinary course of business furnishes information to the credit reporting agency.

Methods for Managing Customer Address Discrepancy

Examples of reasonable policies and procedures enabling a report user to form a reasonable belief concerning a consumer's identity include:

  1. Verifying with the consumer the information in the consumer report provided by the credit reporting agency; or
  2. Comparing the information in the consumer report with information the report user: 
  • (a) Obtains and uses to verify the consumer's identity in accordance with the requirements of the Customer Information Program (CIP),
  • (b) Maintains in its own records, such as applications, change of address notifications, other customer account records, or retained CIP documentation; or 
  • (c) Obtains from third-party sources.

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.

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