Q: Do the requirements of the Address Discrepancy Rules apply to all notices of discrepancy received from any consumer reporting agency?
A: No. The Address Discrepancy Rules only apply to notices of address discrepancy received from an NCRA, which is defined in Section 603(p) of the FCRA, 15 U.S.C. § 1681a(p), as a consumer reporting agency that regularly engages in assembling or evaluating, and maintaining, public record and credit account information for the purpose of furnishing consumer reports to third parties bearing on a consumer’s credit worthiness, credit standing, or credit capacity, regarding consumers residing nationwide. There are only three NCRAs – Experian, Equifax, and TransUnion. Consequently, the Address Discrepancy Rules currently apply only to notices of address discrepancy received from these three NCRAs, either directly or from a third party reseller or procurer acting on behalf of an NCRA (see IV.A.3 below).
A notification of address discrepancy received from an entity that is not an NCRA, however, may be a red flag for purposes of the Red Flags Rules.