ID Theft Red Flags FAQ IVC2 – The NCRAs have provided a code in their reporting for a user to indicate that it is furnishing a confirmed address. Do the Rules require a user to use this field?

Compliance > Lending > FCRA
Q:  The NCRAs have provided a specific code in their reporting formats that permits a user to indicate that it is furnishing a confirmed address for a consumer.  Do the Address Discrepancy Rules require a user to use this field and “flag” that it is furnishing a confirmed address?
 
A:  The Address Discrepancy Rules only require users to develop and implement reasonable policies and procedures for furnishing confirmed addresses.  The Rules do not require users to specially indicate that they are furnishing a confirmed address for the consumer or otherwise specify what mechanism must be used to furnish those confirmed addresses.  However, users may use this code when furnishing a confirmed address to an NCRA.
 
 
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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