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#1116984 - 01/26/09 02:27 PM address discrepancy procedures
Trees Offline
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Registered: 04/22/05
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Anyone willing to share their address discrepancy procedures????

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#1116985 - 01/26/09 02:39 PM Re: address discrepancy procedures [Re: Trees]
Dan Persfull Offline
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Registered: 08/28/02
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Loc: Bloomington, IN
3. Did a consumer reporting agency provide a notice of address discrepancy?

Response(s): The bank will take the necessary steps to form a reasonable belief of the identity of the consumer whom they are dealing with. Once the belief is established The Bank will reconcile the address with the consumer. If the consumer is an existing customer a verbal verification of the address may suffice. If a new customer, including a customer that has paid off previous accounts and is returning for a new one, appropriate documentation such as copies of utility bills, rent/lease agreement, mortgage settlement documents will be required. If the address cannot be reconciled the account will not be opened.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1118391 - 01/28/09 08:06 PM Re: address discrepancy procedures [Re: Dan Persfull]
Trees Offline
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Registered: 04/22/05
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Sounds great. Thanks

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#1149547 - 03/23/09 02:23 PM Re: address discrepancy procedures [Re: Dan Persfull]
lstark Offline
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Is a copy of a utility bill, lease agreement, etc. still required if the address discrepency is only between the application and the driver's license. For example, a potential customer comes into the bank and the address on the application does not match his DL#; however, the consumer report does not show an address discrepancy---should anything be resolved?

How does a CRA and EFunds get an updated address--is this provided by the consumer or through other means? Thanks

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#1149640 - 03/23/09 03:58 PM Re: address discrepancy procedures [Re: lstark]
swiggles Offline
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At my bank, applications for consumer loans are submitted to a central underwriting department that initially obtains the credit report. If a discrepancy is noted on the credit report, how, when and by whom should the discrepancy be resolved? Many consumer loan applications are taken by phone by our call center.

One way to resolve an address discrepancy would be at closing, if the loan is approved. However, we are wondering if it would not be better to resolve the discrepancy prior to underwriting.

Any opinions?
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#1149718 - 03/23/09 04:57 PM Re: address discrepancy procedures [Re: swiggles]
Mrs. Rizzo Offline
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Our procedures require the customers correct address/identity to be FIRMLY verified. If there is a substantial discrepancy, we have a form that the LO must use. The form takes them through the "verification" process.
We don't have anything that stops the loan from being done on the front end but Audit writes them up for not following procedure.


Edited by Rizzo (03/23/09 04:59 PM)
Edit Reason: I can't spell this morning.
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#1149761 - 03/23/09 05:42 PM Re: address discrepancy procedures [Re: Mrs. Rizzo]
swiggles Offline
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But there is no verification required unless the loan is approved.....right? The verification is typically done at closing? Sometimes, that's the first we see of a customer in the flesh.

Our problem is that the staff that take applications for consumer loans (in person) are nothing more than sales staff (CSRs) trained regarding how to take an application and how to close a loan.....kind of like a glorified teller sitting at a desk or a new accounts specialist. These people are not loan officers, they don't make credit decisions and they never see the credit report. Only the underwriting staff in the credit department see the credit report (and the address discrepancy). I'm trying to determine if the underwriter should require proof from the applicant (through the CSR) before proceeding with the underwriting or if the underwriter should just proceed and if approved, the CSR closing the loan would be responsible for obtaining the proof.
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#1150059 - 03/23/09 10:33 PM Re: address discrepancy procedures [Re: swiggles]
Mrs. Rizzo Offline
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I would. Seems like waiting till closing is too much after the fact????
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#1150186 - 03/24/09 01:41 PM Re: address discrepancy procedures [Re: Mrs. Rizzo]
Dan Persfull Offline
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Registered: 08/28/02
Posts: 45493
Loc: Bloomington, IN
I would agree that the sooner the discrepancy is reconciled the less chance of errors. However, the requirement is to reconcile the discrepancy before opening the account, therefore if you are "comfortable" with not reconciling the discrepancy until the applicant sits down across from the "CSR" to close the loan then that is fine as long as it is resolved before the loan is closed. My concern with this set-up is the training mentioned for these CSRs (they are basically order takers) and do they have the ability to actually reconcile the discrepancy, or are they going to take whatever document is presented just to get the loan closed?

Again as long as the discrepancy is resolved before opening the account, when you resolve it is a matter of your operational procedures. Just be sure those procedures are adequate and the personnel performing them are adequately trained.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1152329 - 03/26/09 08:22 PM Re: address discrepancy procedures [Re: Dan Persfull]
CSB98 Offline
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Registered: 12/03/03
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Loc: Wisconsin
Back to this issue, if there is a discrepancy based on information in a credit report, is it the bank's responsibility to contact the CRA and get the address corrected?

Also, in our area a lot of our addresses start with a letter (e.g. N3742 Elm Drive). The credit report may only have 3742 Elm Drive, so then it shows up as a discrepancy. Would you consider this a red flag and show documentation of it being resolved? Should we take the time to change these with the CRA?

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#1152567 - 03/27/09 01:14 PM Re: address discrepancy procedures [Re: CSB98]
Dan Persfull Offline
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Loc: Bloomington, IN
If the CRA reports a "substantial address" difference/discrepancy it must be resolved and it is your responsibility to report the correct address to the CRA. See .82(d)

(d) Consumerís address. (1)Requirement to furnish consumerís 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
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#1161760 - 04/10/09 05:54 PM Re: address discrepancy procedures [Re: Dan Persfull]
this is it Offline
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Registered: 06/05/06
Posts: 92
Has anyone received instructions on how to submit to the CRA the corrected address? Our core processor does not have that option currently available. Any ideas/comments?

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#1165521 - 04/17/09 03:41 PM Re: address discrepancy procedures [Re: this is it]
LostFan Offline
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Registered: 02/24/04
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Loc: New Jersey
I too would be interested in learning how others are submitting a corrected addressto the CRA.

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#1178053 - 05/07/09 04:29 PM Re: address discrepancy procedures [Re: LostFan]
this is it Offline
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Registered: 06/05/06
Posts: 92
UPDATE - Fiserv Vision just announced an update to its Metro 2 report where an updated address indicator will be included. This is due in its June 9th release.

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#2102406 - 10/07/16 08:57 PM Re: address discrepancy procedures [Re: Dan Persfull]
Compliance Offline
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Registered: 09/29/15
Posts: 33
Can you provided an insight as to 1022.82(d)(2)? Is the notice of address discrepancy a separate notice/letter or part of the credit report? How is the address supposed to be confirmed back to the NCRA at the time the account is opened and as part of the Metro 2 report?

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#2102410 - 10/07/16 09:50 PM Re: address discrepancy procedures [Re: Compliance]
'Lil Freak! Offline
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I audited our institution on this a couple weeks ago. I'm not sure of all the specifics so you may need to review documentation from your core processor.

In the event of a credit report address discrepancy the financial institution is required to report back to the NCRA the address was confirmed/verified if a continuing relationship is established. According to the CDIA this is made possible through the Metro 2 format using an Address Indicator code of C (for confirmed).

When our FSRs pull a credit report the origination system requires the address variance to be manually cleared. At that point the FSR validates the address with the applicant and keys a code into our core software. Monthly, a Metro 2 file is sent to the NCRAs with the appropriate field showing the address has been confirmed.
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#2102412 - 10/07/16 10:05 PM Re: address discrepancy procedures [Re: 'Lil Freak!]
Compliance Offline
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Registered: 09/29/15
Posts: 33
What does a NCRA address discrepancy look like? Is it a code, a flag on the report, or a separate notice?
Does the 'confirm' have to be submitted prior to continuing with the current transaction or just in the monthly reporting?
I REALLY appreciate your help.

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#2103109 - 10/14/16 07:32 PM Re: address discrepancy procedures [Re: Compliance]
'Lil Freak! Offline
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Posts: 10589
Loc: The psych ward
I have some older procedures with an example so I'm not sure if things have changed since then. However, on our consumer loan credit bureau (we were using Equifax at the time) it shows as "Address Variance Returned From Bureau." For tri-merged mortgage bureaus each NCRA reports something slightly different. Equifax, for example, shows: "ADDRESS DISCREPANCY: A SUBSTANTIAL ADDRESS VARIANCE OCCURRED" while Trans Union shows: ADDRESS DISCREPANCY: TU ALERT SUBJECT - CURRENT ADDRESS INPUT VALUE DOES NOT MATCH FILE."

The warnings show under the "Additional Information" section of the report.
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