We have a home loan customer who prosecutes high profile drug crimes. She does not want her loan reported to any credit bureau because she is afraid one of the individuals she is prosecuting may use her credit report to obtain her home address. Unfortunately, we already reported the loan to our credit bureau, including the address. Is there anything we can do to “recall” the report or update it to redact her address?

We are not aware of any method for recalling information that has been reported to a credit bureau.

However, under the Fair Credit Reporting Act (FCRA), credit reporting agencies can add fraud alerts to consumer files that block the release of consumer information upon the consumer’s request. We recommend that your customer contact the national reporting agencies and place a hold on the dissemination of her information.

We are less clear on whether credit reporting agencies would agree to redact a consumer’s address from their files. Notably, the FCRA requires credit reporting agencies to notify requesters of consumer credit information when the consumer’s address in the request is substantially different from the address the agency has on file. Consequently, even if the reporting agency does not include your customer’s address in its credit reports, requesters still could be entitled to find out if there is a discrepancy between the address included in a request and the address in the reporting agency’s file.

We also should note that Illinois is one of the few states that authorize land trusts, which replace the identities of owners of real property in public files with the name and address of an institutional trustee. In light of the facts here, you may want to suggest that your customer transfer title of her home to a land trust.

Finally, we note that credit reporting agencies are permitted to release credit reports only for a limited number of permissible purposes, and that the FCRA provides criminal sanctions against any person who knowingly obtains information from a consumer reporting agency under false pretenses.

For resources related to our guidance, please see:

Fair Credit Reporting Act, 15 USC 1681c–2 (“Except as otherwise provided in this section, a consumer reporting agency shall block the reporting of any information in the file of a consumer that the consumer identifies as information that resulted from an alleged identity theft . . .”)

Fair Credit Reporting Act, 15 USC 1681c–1 (“Upon the direct request of a consumer, or an individual acting on behalf of or as a personal representative of a consumer, who asserts in good faith a suspicion that the consumer has been or is about to become a victim of fraud or related crime, including identity theft, a consumer reporting agency . . . that maintains a file on the consumer and has received appropriate proof of the identity of the requester shall . . . include a fraud alert in the file of that consumer . . .”)

Fair Credit Reporting Act, 15 USC 1681c(h)(1) (“If a person has requested a consumer report relating to a consumer from a consumer reporting agency . . . the request includes an address for the consumer that substantially differs from the addresses in the file of the consumer, and the agency provides a consumer report in response to the request, the consumer reporting agency shall notify the requester of the existence of the discrepancy.”)

Land Trustee as Creditor Act, 765 ILCS 415/1 (“For a number of years, the State of Illinois has recognized a real estate trust commonly known as a ‘land trust’. . .”)

Fair Credit Reporting Act, 15 USC 1681b (“[A]ny consumer reporting agency may furnish a consumer report under the following circumstances and no other . . .”)

Fair Credit Reporting Act, 15 USC 1681q (“Any person who knowingly and willfully obtains information on a consumer from a consumer reporting agency under false pretenses shall be fined under title 18, imprisoned for not more than 2 years, or both.”)