I recently completed some monitoring on our Consumer Loan portfolio for Credit Bureau alerst. And of course, I noted exceptions with their process (developed in 2004) for resolving, documenting, etc alerts on credit bureaus. I am telling them that they need to have procedures in place to identify their customer. They are telling me, that they were working under the assumption that the bureau alert procedures only apply to approved loans (i.e., establishing a new credit plan or extension of credit).

My argument is that at the time that they are looking at the credit bureau they may or may not know if they are going to approve or deny the loan. My other argument is that the person applying for the loan may be the identify thief and if they do nothing with regard to a bureau alert, and they deny the loan, then they have compromised the real customer's credit history (their bureau now shows inquiries that they did not make). (I gave in to the credit score denials where no human ever looks at the application on our automated system).

Who is right? Credit Bureau alert procedures apply to all loan requests (my scenario) or just to approved loans (management's scenaraio)?

In the Weekly Banker Briefing for this week, the article on FACTA Verification - Fraud Alert on Credit Bureau says:



I am reading this to mean ALL applications not just those that result in an approval. Am I right?

Here's another thread (and links to threads within the thread) that should help you.

Thank you very much.