(A) Treatment of address discrepancies.
(1) Pursuant to 16 C.F.R. § 681.1, the purpose of this division (A) is to establish a process by which the town 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 town has received a notice of address discrepancy.
(2) In the event that the town receives a notice of address discrepancy, the town 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 town 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 town 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 town obtained from third-party sources that are deemed reliable by the relevant town employee.
(b) Verify the information in the consumer report with the consumer.
(B) Furnishing address to consumer reporting agency.
(1) In the event that the town reasonably confirms that an address provided by a consumer to the town is accurate, the town is required to provide such address to the consumer reporting agency from which the town received a notice of address discrepancy with respect to such consumer. This information is required to be provided to the consumer reporting agency when:
(a) The town is able to form a reasonable belief that the consumer report relates to the consumer about whom the town requested the report;
(b) The town establishes a continuing relationship with the consumer; and
(c) The town regularly and in the ordinary course of business provides information to the consumer reporting agency from which it received the notice of address discrepancy.
(2) Such information shall be provided to the consumer reporting agency as part of the information regularly provided by the town to such agency for the reporting period in which the town establishes a relationship with the customer.
(C) Methods of confirming addresses. The town 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 town’s records to verify the consumer’s address;
(3) Verifying the address through third-party sources; or
(4) Using other reasonable processes.
(Prior Code, § 3-1-11) (Ord. 2009-4, passed 5-11-2009)