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Question: If we check and verify information that is in a credit report, does this make us an investigative credit reporter?
Answer: No. You are free to check and verify information in the report just as you are free to verify information that the applicant provides without becoming an investigative credit reporter. The FCRA defines investigative consumer report in §603(e) as one for which information about the consumer's character, general reputation, personal characteristics, or mode of living is obtained through interviews with neighbors, friends or associates of the consumer. This is very different from verifying employment or a payment pattern on credit with another creditor. Also, when you obtain information for your own use, you do not become a credit reporter. FCRA defines a credit reporter as an entity that compiles information and provides it to others - usually for a fee.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 1, 2/04
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