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As most industry folks are aware, the FTC recently pushed out their Red Flags Rule enforcement deadline to August 1, 2009. It is important to note, however, that this extension does not apply to the specific requirement that institutions with covered accounts detect and respond to address discrepancies related to consumer credit profiles. The original November 1, 2008 deadline is, and has been, the line in the sand for this requirement. I recommend that those institutions still working toward a compliant written and operational Identity Theft Prevention Program ensure that they have in place today a process to detect and respond to address discrepancies noted on credit profiles.

One of the handful of mandatory elements in the Red Flag guidelines, which focus on FACTA Sections 114 and 315, is the implementation of Section 315. Section 315 provides guidance regarding reasonable policies and procedures that a user of consumer reports must employ when a consumer reporting agency sends the user a notice of address discrepancy. A couple of common questions and answers to get us started: 1. How do the credit reporting agencies display an address discrepancy? Each credit reporting agency displays an “address discrepancy indicator,” which typically is simply a code in a specified field. Each credit reporting agency uses a different indicator. Experian, for example, supplies an indicator for each displayable address that denotes a match or mismatch to the address supplied upon inquiry. 2. How do I “form a reasonable belief” that a credit report relates to the consumer for whom it was requested? Following procedures that you have implemented as a part of your Customer Identification Program (CIP) under the USA PATRIOT Act can and should satisfy this requirement. You also may compare the credit report with information in your own records or information from a third-party source, or you may verify information in the credit report with the consumer directly. In my last posting, I discussed the value of a risk-based approach to Red Flag compliance. Foundational to that value is the ability to efficiently and effectively reconcile Red Flag conditions…including addressing discrepancies on a consumer credit report. Arguably, the biggest Red Flag problem we solve for our clients these days is in responding to identified and detected Red Flag conditions as part of their Identity Theft Prevention Program. There are many tools available that can detect Red Flag conditions. The best-in-class solutions, however, are those that not only detect these conditions, but allow for cost-effective and accurate reconciliation of high risk conditions. Remember, a Red Flag compliant program is one that identifies and detects high risk conditions, responds to the presence of those conditions, and is updated over time as risk and business processes change. A recent Experian analysis of records containing an address discrepancy on the credit profile showed that the vast majority of these could be positively reconciled (a.k.a. authenticated) via the use of alternate data sources and scores. Layer on top of a solid decisioning strategy using these elements, the use of consumer-facing knowledge-based authentication questions, and nearly all of that potential referral volume can be passed through automated checks without ever landing in a manual referral queue or call center. Now that address discrepancies can no longer be ignored, this approach can save your operations team from having to add headcount to respond to this initially detected condition.

Back during World War I, the concept of “triage” was first introduced to the battlefield. Faced with massive casualties and limited medical resources, a system was developed to identify and select those who most needed treatment and who would best respond to treatment. Some casualties were tagged as terminal and received no aid; others with minimal injuries were also passed over. Instead, medical staff focused their attentions on those who required their services in order to be saved. These were the ones who needed and would respond to appropriate treatment. Our clients realize that the collections battlefield of today requires a similar approach. They have limited resources to face this mounting wave of delinquencies and charge offs. They also realize that they can’t throw bodies at this problem. They need to work smarter and use data and decisioning more effectively to help them survive this collections efficiency battle. Some accounts will never “cure” no matter what you do. Others will self-cure with minimal or no active effort. Taking the right actions on the right accounts, with the right resources, at the right time is best accomplished with advanced segmentation that employs behavioral scoring, bureau-based scores and other relevant account data. The actual data and scores that should be used depend on the situation and account status, and there is no one-size-fits-all approach.
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