Everyone has their address discrepancy program put in place pursuant to the Red Flags rule. When you receive a consumer report from a consumer reporting agency and there's an address discrepancy, you take certain steps as outlined in the rule. But are reports from Chexystems included?
It doesn't appear so.
The address discrepancy procedures outlined in address discrepancy rule apply to national consumer reporting agencies, as they are defined in section 603(p) of the FCRA. If you review the examiner guidance issued on the address discrepancy rule, it lays this out more clearly than in the final regulation. Chexystems is a nationwide specialty CRA as defined in section 603(w) of the FCRA. So they do not fit within the definition of the rule.
The devil, as they say, is in the details.
For those of you who need all the Red Flags help you can get, check out this Red Flags treasure trove from Bankers Online.
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SHAMELESS PLUG ALERT! Next Wednesday, NAFCU will host a BSA training program (via webcast) designed for your general staff. This program is designed for the employee who needs annual refresher training or for someone who needs an introduction to BSA Land. Yours truly will provide the live training. It should be fun. My goal is to work the following words or phrases into the session: Boo-yah, Paterno, Phillies, gorilla, and shuffleboard. We also have a CD for purchase that is designed for your volunteers who need BSA training. Read all about it here.
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Have a great weekend everyone. (Especially you Texas Tech and Arkansas State fans!)
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