New Info CRA for Address Discrepancy (Fact ID)?

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Question:

If a bank, in the normal course of business does not regularly supply information to a CRA on consumers, are they required to provide new information as a result of an address discrepancy under Fact Act ID Theft?

Answer:

No. One of the requirements for reporting:

Regularly and in the ordinary course of business furnishes information to the consumer reporting agency from which the notice of address discrepancy relating to the consumer was obtained.

If you don't normally report, there is no requirement to do so.

First published on BankersOnline.com 1/14/13