ID Theft Red Flags FAQ IVB2 – If the user plans to deny an application on the basis of info in a consumer report, must a user that receives a notice of address discrepancy establish a reasonable belief that the report relates to the consumer?

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Q:  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?
 
A:  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.
 
 
ADDITIONAL INFORMATION:
This information was obtained from the Interagency FAQs for Identity Theft Red Flags and Address Discrepancies - https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20090611a1.pdf
 

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