New Fair and Accurate Credit Transactions Act (FACTA) requirements now in effect 

On November 1, 2008, new FACTA "red flag" identity theft requirements, which include provisions related to address discrepancy flags in consumer credit reports, went into effect.

Credit report users are required to implement policies and procedures that enable them to form a “reasonable belief” that a consumer credit report they obtain relates to the consumer for whom they have requested the report, when they receive a notice of address discrepancy. 

Therefore, when you obtain a borrower credit report containing a notice of address discrepancy, you must verify the identity of the borrower by:

• Verifying the address with the customer;
• Reviewing internal records;
• Using third party sources; or
• Other reasonable means

If you have questions regarding your responsibilities for complying with these requirements, you should contact your legal counsel.      

For more information on these requirements review the Federal Trade Commission press release.