Section 315 of FACTA requires institutions that utilize consumer reports (“users”) to develop and follow certain procedures when notified of an address discrepancy  by a national CRA (Equifax, Experian and TransUnion). Under FACTA, national CRAs are required to issue a “notice of address discrepancy” when an address provided by a user requesting a consumer report “substantially differs” from the address the CRA has on file for that consumer. The Address Discrepancy Rule then requires users of consumer reports to develop and implement written policies and procedures to respond to receipt of a discrepancy notice. There are two components to the policies required by the Rule: the first relates to the user’s evaluation of the address discrepancy; the second relates to the user’s potential obligation to report the consumer’s address to the CRA.