http://www.bankersonline.com/forum/ubbth...e=0#Post1044644

Please see also and post to the thread above. It regards notififcation to the credit reporting agency upon resolution of an address discrepancy for a new deposit account customer. I posted the topic in the Patriot Act forum before I discovered the flags were being discussed in this forum.

I received release notes from our core support yesterday. The new release is scheduled to be shipped September 30th. From the document:



They go on to say that an enhancement to the Metro formats will be made when the CDIA has fully defined the use of the code and when the credit bureau agencies develop the functionality to utilize the field. Until that time, banks are "urged" to define a response to the address reconciliation within their written identity theft program.

Oh how nice...

"Until that time, banks are "urged" to define a response to the address reconciliation within their written identity theft program."

So....how are you planning to do that?

That's my question too?!?!

Our core provider also says they have no plans to do any upgrades to utilize the new Metro fields.

Our core provider has just said that one of their future releases will allow us to report confirmed addresses to the credit bureau (via the file build programming). They are saying that this is not a requirement, only that we may report a confirmed address, and therefore capability won't be available at this time. How else can we report this information if it isn't done through our normal monthly file that is generated from our core system and sent to the credit bureau?

I'm trying to figure out what we're going to do with this too. We do not report to any of the credit bureaus, we're just too small to feel the need to do so. Plus, if they're not capable of accpeting back a corrected address, what's the point? It's going to be a hard sell for me right now.

If you don't regularly report information to the credit bureaus, you don't have to report confirmed addresses.

Thank you for letting me know that. Can you tell me where this is stated (it will make me feel better to have proof)?

FRB's Regulation V (Fair Credit Reporting Act) - Part 222.82(d) states:

(d) Consumer's address. —(1) Requirement to furnish consumer's address to a consumer reporting agency. A user must develop and implement reasonable policies and procedures for furnishing an address for the consumer that the user has reasonably confirmed is accurate to the consumer reporting agency from whom it received the notice of address discrepancy when the user:
(i) Can form a reasonable belief that the consumer report relates to the consumer about whom the user requested the report;
(ii) Establishes a continuing relationship with the consumer; and
(iii) 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.

We pull credit reports from a CRA for both loans and deposits. We regularly and in the ordinary course of business furnish information to the CRA from which the discrepancy relating to the consumer was obtained, because we report on loans monthly. Neither we nor the CRA have a pre-existing process in place to report deposit account info to the CRA. Yet, we do "regularly and in the ordinary course of business furnish information to the CRA from which the discrepancy relating to the consumer was obtained," regardless of what account type was involved in the notice of discrepancy.

*bump*
Still wondering if there is any news on the idea of a) being required to report resolutions of address discrepancies to CRAs in connection with the opening of deposit accounts and b) how we are planning to do that since the CRAs aren't planning for it to happen.

I asked this question to our CRA rep. and she shared that no FI reports on deposit accounts.

We don't currently report on deposit accounts "in the ordinary course of business" and we don't plan to begin.

Scuttlebutt from a fairly reliable source is that the Big 3 (E, E, and T) and their attorneys are in conference with the FTC, negotiating the following:

For FIs who have split personalities (i.e., a bank which owns an entirely separate corporation which does all the loans and mortgages), the side of the FI that does not "regularly and in the ordinary course of business" report to the NCRA (i.e., the deposit side) will not have to report the resolution of address discrepancies regarding deposit accounts to NCRAs.

But, for those community institutions who have only one entity (the FI itself) that does all the lending, mortgages, deposits, and everything, then the entire bank will be required to report resolutions of address discrepancies to the NCRAs, even on deposit accounts. While the deposit account operations office certainly does not "regularly and in the ordinary course of business" report to the NCRA, the bank does, because its loan side does. Sucks to be us.

In the meanwhile, nothing has been announced yet, so I am preparing to start mailing the NCRAs our notices of which addresses we verified for deposit customers, since the NCRAs are unprepared to accept that data electronically. For the record, I agree that the regulation requires creditors and financial institutions to provide the data, and it stinks that another loophole is being lobbied which will primarily benefit megabanks.

What address will you be using to mail the address corrections to? The address that we use on declinations, or some other address?

We'll probably have to do mail a letter also because I can't see our processor generating something electronically without charging us a ton of money to do so.

We are a small community bank, and do send monthly electronic reporting to a CRA. Included in that monthly file is the customer's address and we had understood that providing the correct address is all we were required to do. Our processor has notified us they have added the field in the CRA file, to indicate the address was confirmed/reconciled ("C") however their documentation refers to it as an optional field. Are we making this too simple? It would definitely be a royal problem to mail notice to the CRAs.

You are not required to mail a notice to the CRA, you are only required to report the correct address through your normal and ordinary course of business in providing information to the CRA.

From the Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions Act of 2003;
Final Rule - Federal Register Friday November 9, 2007;

The Agencies have modified this section as follows . . . procedures for furnishing an address for the consumer that the user has reasonably confirmed is accurate to the CRA when three
conditions are present.

The first condition, in § _.82(d)(1)(i), has been revised to be consistent with the earlier changes in section § _.82(c) that focus more narrowly on accuracy and require that a user form a reasonable belief that a consumer report relates to the consumer about whom it requested the report.

The second condition, in § _.82(d)(1)(ii), now applies only to new accounts and states that a confirmed address must be furnished if the user ‘‘establishes’’ a continuing relationship
with the consumer.

The third condition, in § _.82(d)(1)(iii), has been adopted in the final rule without substantive change.

the third condition, in proposed § _.82(d)(1)(iii), provided that
if the user regularly and in the ordinary course of business furnishes information to the CRA from which a notice of address discrepancy pertaining to the consumer was obtained, the consumer’s address must be communicated to the CRA as part of the information the user regularly provides.

I hope Mr. Persefull is right. For now, my regulator does not agree. For addresses, they have various P.O. Boxes to choose from, i.e.
http://www.fightidentitytheft.com/credit_bureaus.html

It probably doesn't matter which of their addresses is used because they don't plan to accept or use the data anyway. Not that their position will help me any with my regulator.