Identification requirements
when requesting a Full File Disclosure

 

When requesting a full file disclosure, the FCRA mandates that CRAs require the consumer to supply “proper identification” in order to receive the consumer report. The law states “the information the consumer supplies must be sufficient to enable the CRA to match the consumer with its files” but does not state what is technically required…

When requesting a full file disclosure, include an ‘identification sheet‘.

Be sure your identification sheet includes:
– Full legal name
– Any other names
– Date of birth
– Phone number
– Social security number?
– Copy of driver license
– Copy of a bill with your name and address – this is just added measure

The copy of the driver license and bills aren’t technically necessary but they add proof that makes your identity unarguable.

What about Social Security Number?

CRAs will routinely ask for a Social Security Number. Regulation V cites the SSN as an example of a potentially reasonable request for information – however – the reasonableness of such requirement could also depend on whether such information is necessary for the CRA to match the consumer to the file.

Here is the gripe: The records CRAs hold for background checks do not even contain social security numbers. Consumers don’t want to unnecessarily flaunt a SSN because it raises their risk for identity theft.

When a CRA asks you to submit your SSN, assuming you sent all of the identifiers listed above, they are just creating another roadblock to keep you from obtaining your full file disclosure. This could open the CRA up to legal repercussions if you so choose to pursue such a route..

 

The simple answer is use our identification template and you’ll be good to go.