[This article shall be known as the] treatment of address discrepancies.
(Ordinance 2020-29 adopted 10/20/20)
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.
(Ordinance 2020-29 adopted 10/20/20)
The City of Buda.
A notice sent to a user of a consumer reporting agency pursuant
to 15 U.S.C. § 1681c(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.
(Ordinance 2020-29 adopted 10/20/20)
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:
(1)
Compare the information in the consumer report with:
(A)
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;
(B)
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
(C)
Information the city obtains from third-party sources that are deemed
reliable by the relevant city employee; or
(2)
Verify the information in the consumer report with the consumer.
(Ordinance 2020-29 adopted 10/20/20)
(a)
In the event that the city reasonably confirms that an address provided
by a consumer to the city is accurate, the city is required to provide
such address to the consumer reporting agency from which the city
received a notice of address discrepancy with respect to such consumer.
This information is required to be provided to the consumer reporting
agency when:
(1)
The city is able to form a reasonable belief that the consumer report
relates to the consumer about whom the city requested the report;
(2)
The city established a continuing relation with the consumer; and,
(3)
The city regularly and in the ordinary course of business provides
information to the consumer reporting agency from which it received
the notice of address discrepancy.
(b)
Such information shall be provided to the consumer reporting agency
as part of the information regularly provide by the city to such agency
for the reporting period in which the city establishes a relationship
with the customer.
(Ordinance 2020-29 adopted 10/20/20)
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:
(1)
Verifying the address with the consumer;
(2)
Reviewing the city’s records to verify consumer’s address;
(3)
Verifying the address through third party sources; or
(4)
Using other reasonable processes.
(Ordinance 2020-29 adopted 10/20/20)
