Collector - February 2016 - 20


debts are obvious, such as with credit card
debt. But the issue can get murky, such as
with medical debts when the patient didn't
consent to treatment.
Make sure your collectors know how
permissible purpose is defined before they
pull a consumer report.
"An agency may not know what's in their
inventory," Warshaw said. "You could be
pulling credit reports on people where you
really do not have a permissible purpose.
The agency may have collections for fines
and tickets where a permissible purpose to
pull a credit report may not exist, along with
voluntary consumer transactions where a
permissible purpose may exist. As such,
your internal policy must be smart enough
to distinguish when a credit report may be
pulled versus when it may not be pulled."

Of course, a debt collector will always have
a permissible purpose to obtain a consumer
report when it has the consumer's express
permission to do so. So if the original contract
with the creditor stipulates the creditor or its
third-party collection agency will access the
consumer's credit file in the event the account
becomes delinquent, the collection agency
would still be able obtain a consumer report
regardless of whether the debt arose from a
voluntary credit transaction.
But life isn't always this cut-and-dry, and
you most likely won't have permission to
pull a report on every single account in your
database. That's why it's essential to create
written policies and procedures that spell
out not only when employees can pull a
consumer report, but who in the company is
allowed to do so.

Once you have decided that you do have a
permissible purpose to pull a report, the only
way to ensure you are pulling the correct
consumer report is by using the consumer's
Social Security number.
"I've seen people pulling credit reports
on the wrong party because they don't have
a Social Security number on file," Warshaw
said. "I recommend to clients that if you
don't have a Social on the file provided by
the client, don't accept the claim. Just close it.
It's very dangerous finding a Social on your
own with another product, and pulling a
report based on that."
The FCRA also allows consumers who
believe they are victims of fraud to have
consumer reporting agencies place a fraud
alert in their credit files. When this report
is noted on a consumer's file, collection

All of ACA's
Online Training
at One Low Price!
ACA's Training Pass gives you
unlimited access to educational
teleseminars and online
seminars on hot topics such
as operational compliance,
healthcare collections and the
latest from the CFPB.

Enjoy unlimited access
for only $1,149 per year.
Don't miss out on this
tremendous value!

Unlimited
Training

There's no guessing
on your training budget.
$1,149 covers a full 12 months!

Easy Registration

ACA INTERNATIONAL'S

TRAINING PASS
Now a rolling 12-month subscription!

Once you purchase your
Training Pass, you're never
further than a few clicks from
ACA's online education programs.

Invest in Yourself

You haven't come this far
professionally by luck alone. It
takes hard work and education.
Invest in yourself with
ACA's Training Pass!

acainternational.org/
trainingpass

20

ACAINTERNATIONAL.ORG


http://www.acainternational.org/trainingpass http://www.ACAINTERNATIONAL.ORG

Table of Contents for the Digital Edition of Collector - February 2016

Collector - February 2016 - Cover1
Collector - February 2016 - Cover2
Collector - February 2016 - 1
Collector - February 2016 - 2
Collector - February 2016 - 3
Collector - February 2016 - 4
Collector - February 2016 - 5
Collector - February 2016 - 6
Collector - February 2016 - 7
Collector - February 2016 - 8
Collector - February 2016 - 9
Collector - February 2016 - 10
Collector - February 2016 - 11
Collector - February 2016 - 12
Collector - February 2016 - 13
Collector - February 2016 - 14
Collector - February 2016 - 15
Collector - February 2016 - 16
Collector - February 2016 - 17
Collector - February 2016 - 18
Collector - February 2016 - 19
Collector - February 2016 - 20
Collector - February 2016 - 21
Collector - February 2016 - 22
Collector - February 2016 - 23
Collector - February 2016 - 24
Collector - February 2016 - 25
Collector - February 2016 - 26
Collector - February 2016 - 27
Collector - February 2016 - 28
Collector - February 2016 - 29
Collector - February 2016 - 30
Collector - February 2016 - 31
Collector - February 2016 - 32
Collector - February 2016 - 33
Collector - February 2016 - 34
Collector - February 2016 - 35
Collector - February 2016 - 36
Collector - February 2016 - 37
Collector - February 2016 - 38
Collector - February 2016 - 39
Collector - February 2016 - 40
Collector - February 2016 - 41
Collector - February 2016 - 42
Collector - February 2016 - 43
Collector - February 2016 - 44
Collector - February 2016 - 45
Collector - February 2016 - 46
Collector - February 2016 - 47
Collector - February 2016 - 48
Collector - February 2016 - Cover3
Collector - February 2016 - Cover4
http://online.collector.com/collectormagazine/202003
http://online.collector.com/collectormagazine/202002
http://online.collector.com/collectormagazine/202001
http://online.collector.com/collectormagazine/201912
http://online.collector.com/collectormagazine/201911
http://online.collector.com/collectormagazine/201910/
http://online.collector.com/collectormagazine/201909/
http://online.collector.com/collectormagazine/201908/
http://online.collector.com/collectormagazine/201907/
http://online.collector.com/collectormagazine/201906/
http://online.collector.com/collectormagazine/201905/
http://online.collector.com/collectormagazine/201904/
http://online.collector.com/collectormagazine/201903/
http://online.collector.com/collectormagazine/201902/
http://online.collector.com/collectormagazine/201901/
http://online.collector.com/collectormagazine/201812/
http://online.collector.com/collectormagazine/201811/
http://online.collector.com/collectormagazine/201810/
http://online.collector.com/collectormagazine/201809/
http://online.collector.com/collectormagazine/201808/
http://online.collector.com/collectormagazine/201807/
http://online.collector.com/collectormagazine/201806/
http://online.collector.com/collectormagazine/201805/
http://online.collector.com/collectormagazine/201804/
http://online.collector.com/collectormagazine/201803/
http://online.collector.com/collectormagazine/201802/
http://online.collector.com/collectormagazine/201801/
http://online.collector.com/collectormagazine/201712/
http://online.collector.com/collectormagazine/201711/
http://online.collector.com/collectormagazine/201710/
http://online.collector.com/collectormagazine/201709/
http://online.collector.com/collectormagazine/201708/
http://online.collector.com/collectormagazine/201707/
http://online.collector.com/collectormagazine/201706/
http://online.collector.com/collectormagazine/201705/
http://online.collector.com/collectormagazine/201704/
http://online.collector.com/collectormagazine/201703/
http://online.collector.com/collectormagazine/201702/
http://online.collector.com/collectormagazine/201701/
http://online.collector.com/collectormagazine/201612/
http://online.collector.com/collectormagazine/201611/
http://online.collector.com/collectormagazine/201610/
http://online.collector.com/collectormagazine/201609/
http://online.collector.com/collectormagazine/201608/
http://online.collector.com/collectormagazine/201607/
http://online.collector.com/collectormagazine/201606/
http://online.collector.com/collectormagazine/201605/
http://online.collector.com/collectormagazine/201604/
http://online.collector.com/collectormagazine/201603/
http://online.collector.com/collectormagazine/201602/
http://online.collector.com/collectormagazine/201601/
http://online.collector.com/collectormagazine/201512/
http://online.collector.com/collectormagazine/201511/
http://online.collector.com/collectormagazine/201510/
http://online.collector.com/collectormagazine/201509/
http://online.collector.com/collectormagazine/201508/
http://online.collector.com/collectormagazine/201507/
http://www.nxtbookMEDIA.com