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Reporting Loan Accounts and New Deposit Accounts
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht
Bios

Question: We DO report new loan accounts to CRAs. We do NOT report new deposit accounts to CRAs. We DO pull credit reports to open deposit accounts. Would we be required to report new addresses to CRAs on those new deposit accounts since we do not report those accounts?

Answer: You are required to confirm the accuracy of the address when you:
  • Can form a reasonable belief that the consumer report relates to the consumer about whom the user requested the report;
  • Establishes a continuing relationship with the consumer; and
  • Regularly and in the ordinary course of business furnish information to the consumer reporting agency from which the notice of address discrepancy pertaining to the consumer was obtained.


Archive of Featured Red Flag Questions


First published on BankersOnline.com 8/15/08



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