Q: What is the relationship between the Address Discrepancy Rules and the Red Flags Rules?
A: There is very little relationship between the substantive provisions of the Address Discrepancy Rules and the Red Flags Rules. The primary purpose of the Address Discrepancy Rules is to enhance the accuracy of consumer reports, while the objective of the Red Flags Rules is to detect and prevent identity theft. Also, the two rules cover different categories of entities. The Address Discrepancy Rules apply to users of consumer reports, while the Red Flags Rules apply to financial institutions and creditors.
The Address Discrepancy Rules focus on whether a notice of address discrepancy may be an indication that a user of a consumer report does not have the correct consumer report for the consumer about whom it requested the report and require the user to provide a confirmed address to the NCRA that supplied the report. However, in some instances, for users of consumer reports that are financial institutions or creditors covered by the Red Flags Rules, that notice of address discrepancy also may be an indication of identity theft and is therefore listed as an example of an identity theft red flag in the supplement to the Red Flags Guidelines.