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#2203306 - 01/17/19 06:31 PM Reporting back to a CRA
mdog76 Offline
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Joined: Jan 2007
Posts: 645
If the bank receives an address discrepancy on a credit report and we clear that discrepancy on our end (verify through third party documentation), is the bank required to report that new address to the CRA or will it all eventually flow to the CRA in the end?

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#2203311 - 01/17/19 06:51 PM Re: Reporting back to a CRA mdog76
rlcarey Offline
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Joined: Jul 2001
Posts: 79,280
Galveston, TX
Section 605 (h) Notice of Discrepancy in Address

(1) In general. If a person has requested a consumer report relating to a consumer from a consumer reporting agency described in section 603(p), the request includes an address for the consumer that substantially differs from the addresses in the file of the consumer, and the agency provides a consumer report in response to the request, the consumer reporting agency shall notify the requester of the existence of the discrepancy.

(2) Regulations

[See also 16 CFR Part 641]

(A) Regulations required. The Bureau shall, in consultation with the Federal banking agencies, the National Credit Union Administration, and the Federal Trade Commission, prescribe regulations providing guidance regarding reasonable policies and procedures that a user of a consumer report should employ when such user has received a notice of discrepancy under paragraph (1).

(B) Policies and procedures to be included. The regulations prescribed under subparagraph (A) shall describe reasonable policies and procedures for use by a user of a consumer report--

(i) to form a reasonable belief that the user knows the identity of the person to whom the consumer report pertains; and

(ii) if the user establishes a continuing relationship with the consumer, and the user regularly and in the ordinary course of business furnishes information to the consumer reporting agency from which the notice of discrepancy pertaining to the consumer was obtained, to reconcile the address of the consumer with the consumer reporting agency by furnishing such address to such consumer reporting agency as part of information regularly furnished by the user for the period in which the relationship is established.
The opinions expressed here should not be construed to be those of my employer:

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#2212580 - 05/01/19 05:34 PM Re: Reporting back to a CRA mdog76
ckme Offline
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Joined: Sep 2002
Posts: 244
Does anyone have procedures on how to actually "furnish" the address? Our reporting from the core has the address we use for the customer in the metro 2 base segment. Now that I am digging around, I see there is an "address indicator" field. It looks like we leave it blank.

Does simply reporting the loan with the address we use satisfy our obligation or do we have to submit a code when there was an address discrepancy?

The options through our core are Address Indicator - Contains values for the address reported in fields 40-44:

Y = Known to be address of primary consumer

N = Not confirmed address

B = Business address - not consumer's residence

U = Non-deliverable address/Returned mail

D = Data reporter's default address

M = Military address

S = Secondary Address

P = Bill Payer Service - not consumer's residence

If indicator not available or unknown, blank fill.

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