Team VADA eViews
The Digital Newsletter of Your Virginia Automobile Dealers Association
May - June 2008
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Dealers must comply with Address Discrepancy Rule by November 1
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Affects dealership procedures regarding addresses and credit reports
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Purpose is to help identify identity theft
The FTC Red Flag Rule is not the only new regulation with which a dealer must comply by November 1, 2008. The FTC has also issued an address discrepancy rule. What is that?
Under the rule, a notice of address discrepancy is a notification by a credit reporting agency that there is a substantial difference between the address for the consumer that the dealer provided to request the credit report and the address in the credit reporting agency’s file for the consumer.
Under the regulation, a dealer must develop and implement reasonable policies and procedures to obtain a correct address from a customer and provide that to a credit reporting agency. If the credit reporting agency provides notification of a difference in the address, the dealer must engage in due diligence to determine why there is a discrepancy and satisfy itself that it is dealing with the correct person.
This is not really an additional obligation to those under the Red Flag Rule. An address discrepancy may be an indication of identity theft. Consequently, it is something a dealer should be looking for anyway under its Red Flag program.