I understand that a bank that reports their consumerloans to the CRA at the end of the month, any address discrepancy related to the consumer's address will be updated once the file is uploaded. On the other hand when a credit report shows an address discrepancy and the bank does not report consumer loans to a CRA,how does that address is updated?

It is not. The requirement to report a confirmed address only applies if you normally report and only if you are reporting to one of the nationwide credit reporting agencies.

Thank you, that is what I understood.

Thank you, that is what I understood.

So by inputting the correct address into our system and reporting to the CRA monthly it meets the requirements under the FACT Act?

If that confirmed address is actually transmitted to the CRA, yes. You might want to make sure that is actually happening. I have yet had a bank prove to me that is it part of the standard data transmission.

That's what I was afraid of, I have a call into our rep, we'll see what he says. Thanks!

The Metro II reporting format has a field titled "Address Indicator" wherein the reporting entity can send a value of a "C" for a Confirmed / Verified address. I think this value was added in 2008 to allow FIs to respond to the address discrepancy flags. It may have been added sooner than that.

Address indicator fields exist in the record for the borrower in the Base Segment and for co-borrowers at a different address in the J2 Segment.

StevenD:

Would those fields be something that my core processor should be able to verify?

Not Steven, but I would think that the review of the actual file being submitted to the CRA would already be part of your required FCRA data integrity processes (Reg. V - Appendix E). If not, it should be.

Thanks Randy!