I'm confused. If we have an existing customer that applies for a new loan and we pull new credit and there is an address discrepancy are we required to do anything? The bank utilizes the FIS program for ID Verification, Red Flags and Address Analysis at the initial account opening. Are we required to pull FIS again? All of our accounts are considered covered accounts.

You need to find out why the discrepancy is there and figure out if the credit report in front of you is really for the individual(s) you pulled it for. Have they recently moved? Data input wrong? Fraud? We see this alert over and over but you still need to investigate.