It's my understanding that the new rules require an address discrepancy to be resolved even if the loan is declined. The intent seems to be that we must identify the person about whom the report relates before using it( the credit report) to make the credit decision. I'm getting push-back from lenders. They feel that the address discrepancy is not relevant if they are denying the loan.
Any support for my views, (or not)?

You are correct.

Section 222.82(c) Reasonable belief. (1) Requirement to form a reasonable belief. A user must develop and implement reasonable policies and procedures designed to enable the user to form a reasonable belief that a consumer report relates to the consumer about whom it has requested the report, when the user receives a notice of address discrepancy.

You have to do this regardless of whether or not you form a continuing relationship with the consumer. The section that requires you to provide the correct address information to the consumer reporting agency only applies if you form a continuing relationship and if you regularly report to the consumer reporting agency.

Thanks, exactly my sentiments.

I was confused when I read the first sentence - "It's my understanding that the new rules require an address discrepancy to be resolved even if the loan is declined" - I don't think the rules require you to resolve the address discrepancy prior to considering the customer for a loan...you do have to apply reasonable polices and procedures to ensure you have the report from the customer you requested..then reconcile the address if the loan is approved...

"The statutory requirement in section 605(h)(2)(B)(i)
that a user form a reasonable belief that
it knows the identity of the consumer
for whom it obtained a consumer report
applies whether or not the user
subsequently establishes a continuing
relationship with the consumer. This is
in contrast to the additional statutory
requirement in section 605(h)(2)(B)(ii)
that a user reconcile the address of the
consumer with the CRA, only when the
user establishes a continuing
relationship with the consumer.