Let’s say the following example exists. Borrower lives in Arizona (in a rental) part of the year and in Florida (in a rental) the other part of the year. Borrower has lived in several different rental houses in Florida.

Borrower applies using his last Florida address and one of the Bureaus notes an address discrepancies based on the borrower’s multiple rental addresses.

The purpose of the loan request is to buy a primary residence in Florida but in a different city.

I know under the Red Flag rules, we have to address the discrepancy noted by the Bureau. Our process is to inform the Bureaus (through our Core) that we have confirmed a true address and this is the address that should be used for all future requests.

In this case, if we just confirm the discrepancy noted on the credit report, we would report the rental address used when applying for credit. However, we know that the “true” address is going to be the property being purchased (we have a purchase contract, insurance documents, etc).

It seems reasonable to think that we would want to report to the Bureaus the property being purchased. However, sometimes reasonableness is not always considered for compliance.

What is everyone doing in this situation? Are you just confirming the address being used to request credit or do you confirm the address being purchased?

Any help would be appreciated.

However, we know that the “true” address is going to be the property being purchased (we have a purchase contract, insurance documents, etc).

It seems reasonable to think that we would want to report to the Bureaus the property being purchased.

What do you do if the sale falls through for some reason?

We have a Red Flags Response Chart - in these situation we document the discrepancy has been reconciled. If the loan closes then we report the new address. If it does not we report the last verified address.