The FCRA as shown in volume 3 of the Fed's Supervisory Service contains only the statute, Background and Summary of the Act and Q&As. However, the FTC's website contains "Appendix to Part 600 - Commentary on the FCRA", with a "current as of May 25, 2006" date. The following passage is on page 32 of the Commentary: "The Section 615(a) notice must include the name and address of the consumer reporting agency's street address, not just a post office box".

The statute uses only the word "address" which seemingly would allow creditors to simply include the PO Box mailing address of the CRA. However, if the Commentary is "enforceable or applicable" for banks, are we mandated to also include the mailing address?

Thank you.

Yes - that has been the standard for examinations since the commentary came out in 1990.

Do any of you have a street address that you use for Equifax when making this disclosure?

Wasn't aware of the need for the street address. Will need one for Transunion and Experian, too.

We have always used the PO Box addresses and haven't had an issue.

This has been a frequently debated issue for us over the years. Several years ago we conversed with the FTC about FCRA regarding the physical vs. Post Office address issue. It was agreed that the world has changed since the original act was enacted and even since the 1990 FCRA Commentary. Now a days most reports are produced by national CRAs. It is very unlikely that a consumer report would be produced by a local CRA or that a consumer would actually visit a national CRA to view/dispute their consumer credit report. Our contact discussed the matter with Clarke Brinckerhoff (actively involved in writing the FCRA Commentary), and they agreed that a Post Office Box would be sufficient for the 615 notice. They are aware that their current position is contrary to the FTC Commentary. Our regulator, many years ago, did have issues with the PO Box being disclosed but it has not been an issue in recent exams. You need to check with your regulator to see if the physical address requirement would be enforced.