This is a question # 3 under section IV. Duties of Users Regarding Address Discrepancies (Address Discrepancy Rules)

Please note the bold text -

How do the Address Discrepancy Rules apply to a reseller or other person that obtains
consumer reports from one or more of the three NCRAs for purposes of resale?

A user of consumer reports that receives a notice of address discrepancy from a reseller or other
person that procures consumer reports for resale (“procurer”) from one or more of the three
NCRAs must comply with applicable portions of the Address Discrepancy Rules. In these
circumstances, the reseller or procurer is acting on behalf of the NCRA.
For all notices of address discrepancy received from such resellers or procurers, the user would
be obligated to develop and implement reasonable policies and procedures to enable it to form a
reasonable belief that the consumer report relates to the consumer about whom it has requested
the report. However, the user must have reasonable policies and procedures to furnish the
consumer’s confirmed address to an NCRA only if the three-prong test set out in 12 C.F.R.
§ __.82(d) and 16 C.F.R. § 681.1(d) of the Address Discrepancy Rules (discussed below in
IV.C.1) applies: in other words, only if (1) the user regularly and in the ordinary course of
business furnishes information to the NCRA from which the notice of address discrepancy was
obtained by the reseller or procurer, (2) the user can form a reasonable belief that the consumer
report relates to the consumer about whom the user requested the report, and (3) the user
establishes a continuing relationship with the consumer. If the consumer report does not indicate
from which NCRA the notice of address discrepancy was obtained (for example, in the case of a
merged report), the user’s reasonable policies and procedures would not need to provide for the
furnishing of confirmed addresses.

Can someone put some light on a "procurer" for resale? (i.g. scenario or example)

And for the second bold section:

Would this include a mortgage loan officer with in a bank?

Thanks in advance!

This is how I see it.



We obtain all our credit reports through CREDSTAR. They "procure" the report from the 3 NCRAs and then re-sell the information to us. If the report they "re-sell" to us has an address discrepancy then we must have procedures in place to establish a "reasonable belief" that the applicant we are dealing with are who they say they are.



If the report we get from CREDSTAR shows an address discrepancy but it does not identify the NCRA that reported the discrepancy then we have no responsibility to report a "confirmed" address because we don't know which NCRA to report it to.



I'm not sure I understand this question. But the rule applies to the lender therefore the lender must insure that all applicable personnel, including loan officers, comply with the Red Flag requirements.

Dan,

Thanks for breaking that out.
I put mortgage loan officer because it is most common they are the ones pulling a tri-merge credit report. But, yes I agree with "Lender".