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#451178 - 11/02/05 04:42 PM FACTA Issues
Midwest Banker Offline
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Cheeseland
We have procedures in place to follow up on credit bureau alerts and so far things are going well, or so I thought. During a recent review of our loan files, the person looking at the credit bureau's noticed a variety of items: deceased person noted, address reported for abuse, additional socials displayed etc.

I'm concerned these items are not being addressed, and to me they fall more under "good customer service" rather than a FACTA Issue.

Has anyone come across these issues and how are you addressing them?

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#451179 - 11/02/05 05:43 PM Re: FACTA Issues
Andy_Z Offline
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Mary Beth often discusses these scenarios as examples in her FCRA type training. What sometimes happens is that we need a credit report, so we pull one. We put it in the file where it belongs. But we don't use it, or sometimes don't know how to read it correctly. Was it the correct report, have you verified the applicants/customers ID and why does it say some data is suspect? These questions must be answered. Otherwise, someone looks really foolish when their charge off request says the loan won't be paid because the customer died 2 weeks before the loan was made.
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#451180 - 11/03/05 09:04 PM Re: FACTA Issues
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Cheeseland
Luckily in these cases I described, the customers are existing to the bank and have had long term relationships however, no one seems to have paid attention to the bureau information and simply processed the loan.

The bureau only states what I mentioned above. Should we be digging further into the bureau or rely on the customer (of course depending on the realtionship)? And should this be considered a customer service issue or would it fall under FACTA? Thanks Andy

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#451181 - 11/04/05 10:27 PM Re: FACTA Issues
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Cheeseland
bump

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#451182 - 11/09/05 05:20 PM Re: FACTA Issues
GreatBlue Offline
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Colorado
It doesn't sound like those would be considered Fraud Alerts as those terms are defined in 605A, so IMO you don't have FCRA issues. However, if you rely on the credit report to verify identity under your CIP, then you have discrepancies that have to be resolved, and the resolution has to be documented.
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#451183 - 11/09/05 05:43 PM Re: FACTA Issues
Midwest Banker Offline
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Joined: Nov 2004
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Cheeseland
I agree GB, it doesn't appear to be a FACTA issue, but I guess I wanted someone else to validate my thinking on this.
IMHO it is good customer service to address these issues as they arise....Thanks

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