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RentGrow believes that most of its customers already have processes that comply with new mandated F.A.C.T. Act Sections 114 and 315 (also known as "The Red Flag Rule"). In this memo, we would like to offer a recap of the regulation and the obligations required to enforce this new policy. The identity theft prevention rules are to be in effect by November 1, 2008.
As your resident screening company, RentGrow wants to make sure you are aware of this regulation. After reading this, we think you will agree that you are likely already following procedures such as this.
Known commonly as the "Red Flag" and Address Discrepancy Rule, its overall objective is to prompt businesses to take simple steps to authenticate a person's identity when certain warning signs of potential id theft are present. Essentially, to focus attention on discrepancies between what an applicant tells you on their application and the data that a system such as RentGrow's returns to you.
While the rule mainly applies to "financial institutions," "creditors," and "credit card issuers," the National Multi-Housing Council advises that apartment management companies are obliged to comply with one particular portion of the rule. Specifically, Section 315, which requires users of consumer reports to develop "reasonable policies and procedures" that they must apply when they receive a notice of address discrepancy from a consumer reporting agency (like RentGrow or its data providers). Here are two examples: Your RentGrow screening shows a "Checkpoint" address discrepancy message –or- the credit report's address for the consumer is not the same as the address that the applicant listed on his/her application.
The rule requires you to develop and implement "reasonable policies and procedures" so that your leasing agent can form a reasonable belief that his/her applicant is not using false identity information. While the rule does not make it mandatory to have these procedures documented, it is recommended. Here are some examples of reasonable procedures:
When a notice of address discrepancy is received or if a discrepancy is seen, the leasing agent can verify the information in the RentGrow screening with the consumer.
- OR -
When a notice of a discrepancy is seen by or when an address discrepancy is detected by the leasing agent, he/she can compare the information in the RentGrow screening with the following:
- Information found in your own records, such as the leasing application, guest card, and/or driver's license or other official identification.
- Information obtained from other outside sources
(Example: RentGrow offers an address search service that can easily help verify an applicant's address history and social security number. Please contact your RentGrow account manager or sales representative for more information.)
In our experience, most of our customers already follow the first procedure above by calling discrepancies between the RentGrow screening results and the lease application to the consumer's attention. Most of our customers will not offer a lease to parties unable to explain or confirm their address. In conclusion, RentGrow wanted to make sure you are aware of this new rule and wanted to inform you of your need to look for discrepancies between the information provided to you and that returned by RentGrow.
As always, if you have any questions about an applicant's identity – or any part of their screening, you can contact the RentGrow Customer Service team at support@rentgrow.com or by dialing 1-800-736-8476 and choosing option 1 when prompted.
For more information on this policy, please see these links:
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