This article shall be known as "Treatment of Address Discrepancies."
Pursuant to 16 CFR 681.1, the purpose of this article is to
establish a process by which the City will be able to form a reasonable
belief that a consumer report relates to the consumer about whom it
has requested a consumer credit report when the City has received
a notice of address discrepancy.
For purposes of this article, the following definitions apply:
NOTICE OF ADDRESS DISCREPANCY
A notice sent to a user by a consumer reporting agency pursuant
to 15 U.S.C. § 1681(c)(h)(1) that informs the user of a
substantial difference between the address for the consumer that the
user provided to request the consumer report and the address(es) in
the agency's file for the consumer. [NOTE: See 16 CFR 681.1(b).]
In the event that the City receives a notice of address discrepancy,
the City employee responsible for verifying consumer addresses for
the purpose of providing the municipal service or account sought by
the consumer shall perform one or more of the following activities,
as determined to be appropriate by such employee:
A. Compare the information in the consumer report with:
(1) Information the City obtains and uses to verify a consumer's
identity in accordance with the requirements of the Customer Information
Program rules implementing 31 U.S.C. § 5318(1);
(2) Information the City maintains in its own records, such as applications
for service, change of address notices, other customer account records
or tax records; or
(3) Information the City obtains from third-party sources that are deemed
reliable by the relevant City employee; or
B. Verify the information in the consumer report with the consumer.
The City employee charged with confirming consumer addresses
may, in his or her discretion, confirm the accuracy of an address
through one or more of the following methods:
A. Verifying the address with the consumer;
B. Reviewing the City's records to verify the consumer's address;
C. Verifying the address through third-party sources; or
D. Using other reasonable processes.