In an era where financial transactions occur at the click of a button, the significance of accurately verifying and authenticating consumers’ identities cannot be overstated. From online purchases to mobile banking, ensuring secure and reliable digital connections and safeguarding consumers’ information are table stakes for any business operating in the digital ecosystem.
Unfortunately, some advocacy groups are calling for stricter regulatory guidelines that may impede business’ ability to effectively and efficiently protect a consumer’s financial information and identity. We’re, of course, referring to the push to classify credit header data— identifying information, such as name, current and former addresses, phone number and Social Security number, found at the top of credit reports—as a consumer report under the Fair Credit Reporting Act (FCRA).
Subjecting credit header information to the FCRA will unnecessarily limit its permitted use, and effectively make it more difficult—and potentially impossible—for banks and other businesses to use the information to authenticate and verify consumers’ identities. It’s an unintended consequence that will surely compromise the security of our digital identities.
Foundational to fraud prevention
Credit header data plays a pivotal role in helping businesses detect suspicious activity and stay ahead of increasingly sophisticated fraud schemes. With credit header information, banks and other financial institutions cross-reference loan applications against transactions from hundreds of thousands of contributors to spot anomalies and thwart fraudsters before they inflict harm. In fact, many of the industry’s most advanced fraud prevention tools and signals rely on credit header data to verify the legitimacy of any given transaction.
Keep in mind, the transactions we’re referring to are transactions of consequence. For instance, opening a new bank account, applying for a loan or transferring money. This level of activity carries inherent risk, and without proper vigilance, could result in significant financial or reputational harm to consumers and businesses.
But it’s not only lenders that leverage credit header data, the use cases for credit header data are broad. Government agencies and businesses in the public sector, law enforcement, and some pharmacies use the information to issue one-time passcodes for identification purposes, find missing persons, or verify consumers’ identities prior to prescriptions being filled.
Credit header data is already regulated
Some of the concern surrounding credit header data centers on consumer privacy, and rightfully so. Protecting consumers’ privacy should be central to the use of sensitive information; however, credit header data is already regulated by the Gramm-Leach-Bliley Act. In fact, for more than 25 years, the Gramm-Leach-Bliley Act specifically provides that the permissible use of credit header data includes fraud prevention, while also mandating consumer privacy and data protection.
Subjecting credit header data to additional FCRA regulation, which does not clearly allow for fraud prevention, could make it impractical or impossible for many businesses to use it for that purpose. Not only is additional regulation unnecessary, but it potentially creates a contradictory web of regulations that increases the compliance burden and confusion for many businesses. This ultimately thwarts the purpose of GLBA by delaying fraud prevention efforts and potentially raising costs for consumers.
Credit header data is far more than information included at the top of consumers’ credit reports, it is a linchpin that powers many of the most advanced fraud prevention and identify verification tools in the market. Before any further regulation is considered, we have to acknowledge the role that credit header data plays in keeping consumers’ information safe and how any changes may impact the safety and soundness of our digital economy.