FACT Act Red Flags and Address Discrepancies
By Jerod Moyer
What do the new FACT Act Red Flags and Address Discrepancies regulations really say? We've thoroughly researched and picked apart the one-hundred and twenty page final rule and believe it can be summarized as follows:
First, you must implement a written Identity Theft Prevention Program.
Then if you obtain a consumer report, you must form a reasonable belief that the consumer report you received relates to the consumer about whom you requested the report.
Last, if you establish a continuing relationship with the consumer and you normally report information to a credit reporting agency you must:
- Identify and verify any address discrepancies; and
- Report the confirmed address to the credit reporting agency for the reporting period in which the relationship is established.
A one-hundred and twenty page final rules can be overwhelming but it's our job to help you cut through the clutter and get to the "meat". Most regulatory requirements like these can be summed up in a paragraph or two, which makes it much easier for everyone to understand. Sure there are lots of details beyond this summary, but if you understand the big picture, it's easier to read and understand the details.