CRA Processes for Providing Foster Youth Credit Reports

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1 CRA Processes for Providing Foster Youth Credit Reports The following table is originally adapted from a document initially produced by New York City s Administration for Children s Services. It describes each CRA s general procedures for CWAs to request, and the CRAs to return, credit file information for youth in foster care. Information provided below is subject to change. Please contact the CRAs directly if you have any questions or concerns about the processes listed below. What basic information do I need to know to pull credit reports for youth in foster care? TransUnion Confirmed Experian Experian Confirmed Confirmed Equifax Equifax Pending Pending Confirmation Confirmation CRA Contacts Eric Rosenberg, Director Government Relations EROSENB@transunion.com (312) Angela Pescatore fostercare@transunion.com (714) Paul Hernandez Compliance Department Allen, TX (972) paul.a.hernandez@experian.com Troy G. Kubes, Vice President & Associate Group Counsel Equifax Legal Department (678) troy.kubes@equifax.com Gary Poch, Vice President (678) Gary.poch@equifax.com Child and Family Services contact information: (800) CFS@equifax.com Contractual Requirements for CWAs to access reports Each state, county or hybrid agency assigns one Head Designate with administrative rights to the system. The Head Designate may request and receive reports or may delegate access to other appropriate persons within the agency. Private not-for-profit entities that manage foster care youth on behalf of the state may also be set up to request and receive youth credit reports for permissible purposes to comply with the federal law. Each state or county assigns one Head Designate with administrative rights to the system. The Head Designate may request and receive reports or may delegate access to other appropriate persons within the agency. Requires one state-level administrator who manages all administrative and negotiating duties including the creation of sub-accounts for additional agency users. Sub-accounts offer local personnel a private login and password and only have access to data on youth specific to requests that they have made through that login. Data Submission Requirements Youth s Social Security Number (SSN) Youth s SSN Youth s Date of Birth Optional: Other relevant Personal Identifying Information (PII) Youth s SSN

2 Portal v. Manual CWAs use same online portal available to business customers TransUnion Direct CWAs use same online portal available to business customers TransUnion Direct Online portal is now available (launched in June 2013) Continued access to the manual process and consumer file disclosure will be available for those states and CWAs that prefer the manual method Batched v. Individual TU has a specific spreadsheet template that CWAs may use to request credit reports in batches of 50+ youth in their care. CWAs must save and upload the batch request spreadsheet as a.csv file. CWAs may also request a single youth s report individually through TU s online portal, TU Direct, which is TU s preference. Individual reports may be downloaded as pdf files. CWAs may upload batch requests for multiple youth at a time using an Experian template that can be created in Excel and uploaded as a.csv file. CWAs may also request and download pdfs of individual youth reports. CWAs to submit a batch spreadsheet saved as.csv via its online portal. Equifax has not developed a specific template, just data field requirements, for this request. CRA Response Time Results returned immediately for individual requests and within 24 hours for batch requests. Results returned within 5-10 business days by mail. The electronic portal will provide electronic results within 24 hours. Results returned within hours if batched. If inquiries are submitted individually, results are immediate. Format of Response from CRA Results returned on a spreadsheet. If a credit report is found, TransUnion will return it as a separate pdf document for each youth. Experian currently mails paper files for any youth with a file back to the address requested. Once the electronic portal is finalized, individual results will be returned onscreen and an option to print or save as a PDF will be available. For batch processing, options are to receive the results in enhanced html or PDF format and in a single file or individual files for each request. If a report exists for a child, Equifax provides an on-screen credit report that can be printed out. CWAs can receive the reports individually or in bulk via a zip file. 1

3 Type of Report Delivered Both consumer disclosure and business division reports, depending on process. Business report via portal. The business report provided does not include soft inquiries or medical accounts. If the manual (mail-in) option with documentation is used, TU will provide the consumer disclosure report. The disclosure report provides information on creditors and other users that have looked at the consumer s credit report within a 2 year period. The report does not tell the purpose of the search, but it could be an indication of fraud. Both consumer disclosure and business division reports, depending on process.. Currently Experian provides a consumer disclosure file in response to manual requests. The online portal will provide business reports through the batch process; or the consumer file will still be available through a manual process Business division report only (consumer credit report under the FCRA) Information included in the business report will vary based upon the type of contract the CWA has entered into; there is no set standard. Fees Currently waiving all fees. Agencies paying fees pursuant to an existing contract may specifically request a fee waiver moving forward. All fees waived $500 one time set up fee plus a $50 monthly service fee May be possible to request discount or waiver Can I share credit reports I pull for youth in foster care with third parties? In certain cases contractual restrictions with the CRAs may prohibit child welfare agencies from sharing the reports that they pull on behalf of youth with third parties such as nonprofit partners without the explicit, prior consent of the CRAs. The table below summarizes how some CRA contracts may address report sharing and confidential data handling. TransUnion Confirmed Experian Confirmed Equifax Pending Confirmation Third Party Use The youth has the option to disclose a consumer disclosure report that he/she receives from TransUnion with anyone. Authorized agency employees with a legitimate business purpose are allowed to use a youth s report for Authorized agency employees with a need to know and third party processors or agents may be allowed How do I resolve errors, ID Theft or Fraud? The table below summarizes how each CRA may assist CWAs with remediation processes and credit file protections. At the time of this writing, more research is being conducted by CBA to help CWAs address instances of identity theft or other fraud identified through the 2011 federal mandated credit check process for youth in foster care TransUnion Confirmed Experian Confirmed Equifax Pending Confirmation If errors or identity theft are found They have designated two contacts (Angela and Steve) for caseworkers to contact if there is information they need to dispute. They will work with caseworker to clear up the fraud (CWA manager-level contacts are different) CWA can contact furnishers and ask them to contact CRA to remove errors CWA needs to contact Equifax to find out fraud process and to dispute the information. 2

4 TransUnion Confirmed Experian Confirmed Equifax Pending Confirmation Different dispute process for manual v. portal requests? Caseworkers are to present the report to the youth and verify that the information is inaccurate. The caseworker must then provide a written cover letter containing: The youth s information, What information is being disputed Attached copy of a court document showing proof of guardianship This packet should then be mailed back to TransUnion: TransUnion Attn: Foster Care Services 1561 E. Orangethorpe Ave Fullerton, CA No, the same process is used for manual and portal requests. Disputes are sent in writing to the National Consumer Assistance Center (NCAC) at PO Box 9701 Allen, TX Dispute letters should include: Identification information of the youth Contact information for the state agency where results should be sent Copies of the court order authorizing the agency to act on behalf of the youth Details of the disputed information. Equifax offers both an online and manual dispute process. The online process can be accessed here. To dispute a credit report error manually fill out this form and return via mail to Any results of reinvestigation will be mailed if a dispute is submitted manually. Equifax suggests a manual contact for any disputes using the below number or address: Phone: Office of Consumer Affairs Mailing Address: Equifax Information Services, LLC - Minor ChildPO Box Atlanta, GA Full Consumer File Currently not possible unless they use the mail-in manual process. Yes. The caseworker can request a full consumer file disclosure be mailed to them after NCAC is finished with the reinvestigation process regarding the disputed information. A file disclosure will be provided after any dispute and reinvestigation. Clean Up Process Contact TransUnion to determine the options for cleaning up a report on a case-by-case basis. Contact Experian explaining that the youth is a minor and the accounts on the credit report have been opened fraudulently. NCAC, in most cases, can remove the information or in cases where NCAC can t they will contact the source of the data to see if they will remove the incorrect information. Experian will notify the CWA in either case what the results are. Or, the foster agency can contact the source of the data directly and explain the situation and have them remove the information from Experian s reports. Contact Equifax regarding any incorrect information and the specific dispute process. 3

5 TransUnion Confirmed Experian Confirmed Equifax Pending Confirmation Are the dispute, freezing, and/or blocking mechanisms available to caseworkers? 1 Yes. All 3 are available but the caseworker should contact TransUnion first to determine the best option. Yes, all 3 are available, but the blocking mechanism and freezing cannot be used at the same time. Blocking mechanism is for youths that don t have a credit report yet. It is used as a preventative measure. Yes, all 3 are available to caseworkers. Is there a process for parents and guardians to check if their minor children are victims of identity theft? Can foster agencies use this process for foster youth? Parents or guardians can check through TU Online Child Identity Theft portal to see if their child has a report; if a report exists, this could be an indication of identity theft. CWAs can use the same method for checking whether a foster youth has a report. Parents or guardians must use a manual process and provide proof of their identity and their child s information. In some cases, guardians must provide proof of guardianship. CWAs can use this process for foster youth but must provide the court order to establish authorization on behalf of the minor. Parents/guardians must use a manual process and submit legal proof of guardianship in writing to Equifax. 1 Freeze needs to be removed when the youth turns 18 or needs to access credit. 4