Form for Reporting Address Discrepancies Provided by CRAs Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: Will these final rules also apply when financial institutions use credit reports in the hiring process of new employees? Will the CRAs provide a form to report an address discrepancy? Our HR department would not normally report the hiring of an individual so we would not report back the discrepancy.
Answer: Since there is nothing in the regulations that excludes credit reports used for employment purposes, we assume that you must establish policies and procedures for resolving address discrepancies resulting from credit reports obtained for employment purposes. That will likely involve confirming the identity of the new employee, but since information on new employees is generally not reported to a CRA, then the address need not be confirmed to the CRA.
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