Since we cannot use a report that contains an address discrepancy should we deny an application based on the inability to identify the applicant when the discrepancy is not resolved?

If you can't identify the applicant, then you should deny it. However, just because there is an address discrepancy doesn't mean you can't identify them. There are other ways to ensure they are who they say they are.

An address discrepancy is a red flag. It's not a 100% indicator the person is not who they say they are.

If the customer applies and based on the address discrepancy we do not have a reasonable belief the report relates to the person that submitted the application can we use it to deny them? It seems like a waste of time to have them come in to clear it up if we are just going to deny them.

From the Red Flags FAQ from 2009:

2. If the user plans to deny the consumer’s application to open a new account on the basis of information in a consumer report, must a user that receives a notice of address discrepancy take steps to establish a reasonable belief that the consumer report it has obtained relates to the consumer?

Yes. If a user plans to deny the consumer’s application based on a consumer report, the user must take steps to ensure that the consumer report on which it is relying pertains to the consumer.

What if we request further identification and they do not send it? Would we not deny it based on identification and not the credit report?

Unable to confirm identity of the applicant.