I am putting the FCRA Identity Theft and Address Discrepancies into a laymans document for management and I have developed a 'brain freeze'... Can someone tell me the applicability of this regulation to bank Affiliates? We have an Insurance company and a real estate company that funds loans in which the bank purchases.

Thanks,
Lori

From the preamble:

Section 114 applies to financial institutions and creditors. Under the FCRA, the term “creditor” has the same meaning as in section 702 of the Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691a.15 ECOA defines “creditor” to include a person who arranges for the extension, renewal, or continuation of credit, which in some cases could include third-party debt collectors.