SSN Issue

6 Replies

Hey guys,

I have a file where the SSN that was provided to us returns an invalid credit report. The note seller is out of business (no surprise). We don't have the original loan docs in the collateral.

Inside the collateral there's an affidavit stating this couple has about a dozen aliases. The loan was originated in ~2005. Could it be a fake SSN?

How would you go about getting their SSNs?

You really should not be pulling credit on a Borrower without a signed authorization from the Borrower or at the lease verbal authorization.  Credit vendors usually require these.

Additionally, how is the "Seller" out of business?  Who is selling you the loan then?  

Having multiple alias is not uncommon and is not an indication of fraud per se.  "Jim" is an alias for "James" and "Bob" is an alias for "Robert".  Etc.

The cure for an inaccurate SSN is contact the borrower.  If you can't make contact with the Borrower it is like a file you don't need a SSN for anyway.  

Originally posted by @Patrick Desjardins :

Lots of mistaken assumptions, with no actual solution provided. No surprise there. Thanks anyway.

 There are zero assumptions in my post.  

As far as the snide comment about my contribution to the thread.  Other readers can take head to my statements since you know all the answers to the question you asked.   Good luck with that approach.

Obtaining credit report for the purposes of collecting a debt is considered a permissible purpose under the Fair Credit Reporting Act (FCRA).

Are you sure you actually invest in notes? You regularly make statements that make you look like a pretender.

I understand your desire to want to argue here and I further understand how your limited experience may have subjected you to situations where your blanket statement is true.  However that doesn't mean it actually is.   

Most mortgages are closed-end accounts (exception is a HELOC) and as such the terms of the credit extended are fixed in nature. The FTC has openly stated that there is a limitation to use of permissible purpose of reports for mortgagees in an on-going nature.

A good illustration of this is in permissible purpose on defaulted mortgage accounts.  In a non-accrual status the collection of the debt by way of the consumer gives way to recovery from the collateral ergo on-going report needs are limited.  

That limitation can be removed if the consumer/borrower attempts to reinstate the account or applies for modification or relief.  In that setting the consumer/borrower is present to give authorization - which should be done as a compliance best practice.  

In addition, the creditor can obtain a deficiency judgement and then that permissible purpose is established and the report can then be used in the collection activity of that debt.  

In your OP you have a data defect.  The prudent path of resolution is to contact the borrower and cure the defect by verifying the number on record.  I am sure if you contact your credit vendor they will tell you the same exact thing.  In a loan file there are a limited number of documents which contain a borrower's SSN explicitly for protecting the consumer's rights and compliance purposes.  

If you do not own the account the current Mortgagee (the Seller you said was out of business) should do such things as a bidder of a note can be seen to have no permissible purpose until such time as they become the owner.  You are not Bank of America or other institutions who can substantiate their investment desire and credit compliance where-with-all.  The only time a prudent private investor should pull credit as a bidder is with written authorization otherwise the Seller should supply it.

If you are the owner of said account and have pulled credit which returns in error you do not have a free pass to simply try and obtain it from other channels.  That is generally considered a prohibited act.  (See previous statement about contacting your credit vendor to verify that.)  There are regulations on the sharing, storage and conveyance of SSN and credit information on consumers/borrowers.  The error illustrates a flaw in the data that should be cured properly.  Not by guessing where you can get it.

As far a my knowledge, experience and understanding of this industry.  Yea...I just pretend.

Says the guy trying to reconcile credit data defects improperly.  Got it.