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#2171200 - 03/30/18 07:39 PM CIP and Consumer Reports
TheManofSteel Offline
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TheManofSteel
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Fortress of Solitude
If I am CIPing a new deposit account customer, and as part of my verification of ID procedures, use tools provided by what are otherwise consumer reporting agencies, am I correct that does not constitute a consumer report?
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#2171201 - 03/30/18 07:42 PM Re: CIP and Consumer Reports TheManofSteel
rlcarey Offline
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rlcarey
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Galveston, TX
Depends on the tools you are talking about.
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#2171202 - 03/30/18 07:43 PM Re: CIP and Consumer Reports rlcarey
TheManofSteel Offline
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TheManofSteel
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Fortress of Solitude
Just verifying their identity, say, against other sources like Social Security Admin data, maybe also an OFAC screen, as examples.
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#2171203 - 03/30/18 07:47 PM Re: CIP and Consumer Reports TheManofSteel
rlcarey Offline
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rlcarey
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Galveston, TX
How are you accessing SSA information - they have no public data bases. And an OFAC screen does nothing as far as CIP verification.
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#2171204 - 03/30/18 07:50 PM Re: CIP and Consumer Reports TheManofSteel
TheManofSteel Offline
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Utilizing chexsystems, which I think has access to Soc Sec database of numbers of decedents
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"Beneath an ever watchful eye...the angels of the temple fly"

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#2171205 - 03/30/18 07:55 PM Re: CIP and Consumer Reports TheManofSteel
rlcarey Offline
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rlcarey
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Galveston, TX
ChexSystems is a CRA.
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#2171208 - 03/30/18 08:02 PM Re: CIP and Consumer Reports rlcarey
TheManofSteel Offline
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TheManofSteel
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Fortress of Solitude
Yes, but is every product they provide a consumer report as defined in FCRA?
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"Beneath an ever watchful eye...the angels of the temple fly"

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#2171209 - 03/30/18 08:07 PM Re: CIP and Consumer Reports TheManofSteel
rlcarey Offline
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rlcarey
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Galveston, TX
I am not aware of them offering products that are not - but I am no longer on that side of the equation.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2171224 - 03/30/18 09:58 PM Re: CIP and Consumer Reports TheManofSteel
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Look at 603.(d) then look at 604(a)(3)(f)(i).

I'm not sure how you can contend you are not using the information in relation to a business transaction initiated by the consumer.
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