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Address Discrepancies on Credit Reports

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Question: 
Our bank does not report business purpose loans to credit bureaus. If we have an address discrepancy on a credit report pulled for an individual, but the loan is business purpose, are we obligated to furnish the borrower's address under Reg V, once we have reasonably confirmed it as accurate?
Answer: 

First, the fact that the application was for a business loan does not outright exempt you from FCRA requirements, because you did obtain an individual consumer credit report. That said, there are a couple of different FCRA provisions that could apply, depending on what you mean by "address discrepancy on a credit report".

1. Did the credit report simply point out that the address you input (when pulling the credit report) doesn't match the address in the credit reporting agency's records? If so, you "just" have a Red Flag on your hands. See Supplement A to Appendix J, red flag #10 and apply your Red Flag program procedures. If you clear this red flag, you are done.

2. Or, did the credit reporting agency provide you a "Notice of Address Discrepancy", as defined by Reg V 1022.82? If so, look at (d)(1)(i) - (iii) for instructions.

Pay particular attention to criteria (iii), which says you have to furnish the correct address if you "regularly and in the ordinary course of business furnish information to the consumer reporting agency from which the notice of address discrepancy relating to the consumer was obtained." You don't report on business loans, so that means (d)(1) requirements would not apply. (Side note, if this individual also has a consumer loan, you'd already be reporting the address you have on record as part of your normal furnisher file, thereby satisfying this requirement.)

But wait, you aren't done yet! Your receipt of this formal Notice also constitutes its own Reg Flag (#3 in the first link above), and so you'll also need to apply your Red Flag program procedures here too.

First published on 10/08/2023

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