Verifying Information for Loan when the Credit Report is Obtained Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: CIP says that a loan is not an 'account' until the loan closes. Therefore, we check drivers license at closing, before the applicant becomes a customer. Under the FACT Act, how can we verify information when the credit report is obtained and used before closing?
Answer: The regulations indicate that you must form a reasonable belief that a consumer report relates to the consumer about whom you have requested the report, when you receive a notice of address discrepancy.
You may verify the identity with information that you:
Obtain and use to verify the consumer's identity in accordance with the requirements of the CIP rules,
Maintain in your records, such as applications, change of address notifications, other customer account records, or retained CIP documentation; or
Obtain from third-party sources.
You also may verify the information with the consumer.
You have a choice - modify your CIP procedures or adopt another method of verifying the person's identity when you receive an address discrepancy.
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